The National Historic Preservation Act (NHPA) requires federal agencies to consider the effects that a proposed action may have on historic resources and to consult on means to avoid, minimize, or mitigate effects determined to be adverse. For the proposed action, GSA's EA will include a summary of the proposed action's potential impact to cultural resources. In conjunction with GSA's NEPA documentation, GSA' will fulfill its Section 106 responsibilities by conducting consultation with consulting parties to evaluate the potential for effects to the Cotton Annex, the Regional Office Building (ROB), and adjacent and nearby historic resources. In March 2014, the Secretary of the Interior determined that the ROB is not eligible for listing in the National Register of Historic Places.The public will be provided opportunities to comment on the EA, which will incorporate the results from the Section 106 consultation.
GSA has already concluded Section 106 consultation on the 1800 F Modernization, which led to the execution of a Memorandum of Agreement (MOA) with the DC State Historic Preservation Office. The St. Elizabeths West Campus Development Master Plan is the subject of a 2008 Section 106 Programmatic Agreement for the Master Plan. GSA's ongoing Section 106 consultation for projects on the West Campus is reinitiated as each project is designed. GSA will conduct consultation for the rehabilitation of West Campus buildings as the design is developed.