Ed Hathaway discusses The Odd Fellows Hall
September 12, 2000
What follows is the text of an email message I received from Ed Hathaway of the EPA on Monday, September 11, 2000 regarding the preservation of the Odd Fellows Hall.
As we have noted before, Ed and the other EPA officials are always willing to discuss issues regarding the cleanup.
My thanks to Ed for his response. If you have other questions, contact Ed directly or send them to me. I will relay them.
Here is an attempt to clarify the Odd Fellows building situation.
Any federal undertaking is obligated to determine if historic properties are present and may be impacted by the federal activity. This provides a mechanism for the protection of historical and cultural resources that would otherwise be demolished. I have three sites with historic properties: Eastern Surplus in Meddybemps, contains Native American artifacts dating back 7000 years ago; Elizabeth Mine in Vermont is a historical mining landscape; and Eastland Woolen Mill in Corinna has the Odd Fellows building.
The federal law places the burden on the lead federal agency (in this case EPA) to complete the assessment as to whether a historic property is present and whether an adverse effect will occur. A historic property is defined as a property that would be eligible for the National Register of Historic Places. There is a very good web site www.achp.gov for the National Advisory Council for Historic Preservation.
The lead federal agency must hire a qualified consultant to evaluate the presence of historic properties. The agency then uses the professional opinion to notify the State Historic Preservation Officer (SHPO). EPA seeks the concurrence of the SHPO with the determination. If a historic structure is present and an adverse effect will occur, then EPA must develop a Memorandum of Agreement to mitigate the adverse effect.
The criteria require that the lead federal agency avoid adverse effects, if possible, the minimize if not. If destruction is unavoidable, then mitigation is required.
For the Odd Fellows structure, EPA made the determination that it was an eligible structure. The SHPO concurred. EPA then made the determination that an adverse effect was unavoidable, but that moving the structure would have less adverse effect than demolition. Our personal opinions had to be set aside when the regulations are clear.
One final note: The SHPO contacts for the Site have been very professional and pleasant to work with. Your readers should know that they have done all that they could to make sure the cleanup continues and is not delayed. This is one of those situations where the common good that comes from this regulation has consequences for many projects. I just hope we all find a way to preserve the structure after the tremendous investment in re-location and it would also be nice if the public could have access to the interior which is the main features that makes this a historic structure.
I hope this helps. We can discuss further if you would like. You perform an outstanding public service with your web site. I am very grateful for you efforts.
Ed