The key phrase in Section 106 of the NHPA is that any entity receiving Federal funds must “take into account the effect of the undertaking on any district, site, building, structure, or object that is included in or eligible for inclusion in the National Register.” But how does one determine if a property is eligible for listing in the National Register of Historic Places?
A property can be identified to be eligible according to one or more of four eligibility criteria:
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Criterion A - "Association"
According to Criterion A, properties “that are associated with events that have made a significant contribution to the broad patterns of our history…” may be listed as eligible. "[E]vents might refer to a specific occurrence or a more general period as illustrated by the nomination of the Bathhouse at Sand Bar State Park in 1999, determined to be eligible through Criterion A because of its association with the Civilian Conservation Corps (CCC). The CCC played an important role in the development of the United States and at parks like Sand Bar, the development of our landscape, building defining structures such as the Bathhouse (https://vtstateparks.com/sandbar.html)
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Criterion B – “Big People”
Criterion B applies to properties “that are associated with the lives of persons significant in our past…”. As the birthplace and childhood home of our 30th President, the Calvin Coolidge Historic Site in Plymouth, Vermont is listed on the NRHP (https://historicsites.vermont.gov/calvin-coolidge).
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Criterion C – “Characteristics” or “Cute Buildings”
36 CFR 60.4 defines Criterion C as properties “that embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction…”. The fire tower at the top of Elmore Mountain in Elmore State Park is eligible for listing under Criterion A because of its association with President Roosevelt’s Works Progress Administration program, as well as the tower's association with the preservation of fragile resources through the control of forest fires through the American Conservation Movement. However, the Elmore Mountain fire tower is also eligible because the tower is a well-preserved representative of the standard USDA Forest Service fire tower design from the 1930s (http://nhlr.org/lookouts/us/vt/elmore-mountain-fire-tower/).
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Criterion D – “Data”
According to Criterion D properties “that have yielded, or may be likely to yield, information important in prehistory or history” are eligible for listing on the National Register of Historic Places. Archaeologists will typically apply Criterion D when defining archaeological sites as eligible for listing, referring to the significant information that the site might contain about the people that lived on the landscape we now call home over the past centuries and millennia. Archaeological Site VT-CH-1270 at Sand Bar State Park in Milton, Vermont is eligible for listing on the NRHP because of the site's potential to provide information about the pre-Contact history of Vermont and the Champlain Valley, an in particular the wide connections that people living along Lake Champlain in centuries past had with other peoples and places hundreds of miles to the north and south of what today is Milton, Vermont.
It is important to remember that eligibility to the National Register of Historic Places or the Vermont State Register of Historic Places, is not meant to stop change. Rather, eligibility places a property within a consultation process through which we can assess and manage the potential impacts that projects might have on historic resources.
What is the National Historic Preservation Act (NHPA)?
What are “effects” and how might effects be resolved?
[1] King, Thomas
2012 Cultural Resource Laws and Practice, Alta Mira Press, Lanham, MD.
[2] Vermont State Parks
2023 Sand Bar State Park, November 25, 2023, https://vtstateparks.com/sandbar.html.
[3] Agency of Commerce and Commercial Development - State Historic Sites
2023 President Calvin Coolidge Historic Site, November 25, 2023, https://historicsites.vermont.gov/calvin-coolidge.
[4] GoXplr
2023 12 Amazing Vermont Fire Towers, November 25, 2023, https://www.goxplr.com/vermont/vt-fire-towers/.