Section 106 Review in Fairmont

By Robert, Preserve WV AmeriCorps


Citizen Building, photo credit: Robert Wolfe

Over the summer I was able to lead a Section 106 Review for Main Street Fairmont.  For those unfamiliar with Section 106, it is a provision in the National Historic Preservation Act that requires federally funded/permitted projects to “take into account” their impacts on historic places.  In this case “historic” is defined as any building or site eligible for listing on the National Register of Historic Places.  The process can be seen as a way to slow down and see if there is any way to reduce the impacts of construction to historic places, but it does not force an outcome.

For Main Street Fairmont’s project, we were rehabilitating the Citizen Building, an 1880s commercial building and one of the oldest in downtown.  The Citizen Building is not on the National Register of Historic Places but it is a contributing structure to the Downtown Fairmont Historic District.  In addition, funding for our project came from the Natural Capital Investment Fund, a federal grant program under the USDA.  For this reason, we had to undertake a section 106 Review.

Our review process was pretty straightforward.

First we had to define the “Area of Potential Effects” or note the historic structures that would be impacted by the project.  We were making direct changes to a historic building, so our APE was limited to the building itself.  In larger projects, the APE could include the potential for damage by blasting for a road, or having the view from a historic structure or landscape interrupted by a pipeline.

The second step is to gather documentation for our project.  For us, this included submitting our proposed changes to the Citizen Building.  For a non-rehabilitation project, it might be new construction plans or the plan for a highway.  In addition we submitted a letter from the local Historic Review Commission, as evidence that our changes would not impact the historic character or integrity of the building.

Our review project was relatively simple, but there can be a whole host of actions taken for larger projects including surveys for potentially historic buildings and public hearings for how to diminish impacts.  Ultimately a deal for saving a historic place could be reached an Memorandum of Agreement between, but this is not always the case. For more information about what is required for a Section 106 Review please visit ( and for more information about the Section 106 Process in general please check out this handy guide published by the Advisory Council on Historic Preservation (


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