An extraordinary system of cultural and historical resources.

Initiate Section 106 Review

Section 106 Consultation with the Idaho State Historic Preservation Office

A Closer Look

Sample Checklist for Section 106 Information for the Idaho SHPO

Documenting Cultural Resource Surveys **NEW**

Idaho SHPO Survey Report Template **NEW**

To initiate Section 106 consultation with the State Historic Preservation Office (SHPO), the Federal agency (or applicant) is required to submit a cover letter with the following information and attachments.  Technically, this information should come from the Federal agency, but the Federal agency occasionally authorizes applicants for Federal assistance or permits to initiate consultation with the SHPO.

If the project is located within the boundaries of the Nez Perce or Coeur d’Alene Indian Reservations, contact the Tribal Historic Preservation Officer for the respective Tribe.

If the project is taking place on Federal (e.g., U.S. Forest Service, Bureau of Land Management) or Tribal (reservation) land, or if it is a project associated with the Idaho Transportation Department (ITD), it is necessary to consult with the cultural resource professional employed by the land-managing agency, Tribe, or ITD before consulting with SHPO.

Cover Letter

  • Name and contact information of Federal agency or agencies involved.
  • Project description that clearly specifies all project components including details on; (1) Work that will affect the physical characteristics of buildings and structures built before 1970 and their sites.  For example, will windows be replaced?  If so, describe the existing windows and the proposed replacement units.  Will an addition be constructed onto the building?  Where will it be located, and what will it look like? Will the building’s setting be affected?  Will the historic landscape be affected? (2) Work that will involve ground disturbance.  For example, if the project will be replacing water lines or sewer lines, will the new lines be placed in the same trench or will it be new construction?  Will other areas be used, such as staging areas, borrow sources, or disposal areas?
  • Legal description (township, range, and section) or street address of the project’s area of potential effects.
  • Brief description of the condition of the ground surface or any information relating to past construction or heavy equipment work within the project area.  Has the area been bulldozed?  Is it paved or covered with lawn or dense vegetation?  Were there structures located on the property in the past? To investigate, you can consult county assessor records, fire insurance maps, owners or previous owners, or long-time citizens.
  • A brief description (including age) of any buildings or structures that will be involved, altered, or removed during project construction.  If the buildings or structures were built 45 or more years ago, an Idaho Historic Sites Inventory form (with accompanying photographs and a map) needs to be attached.
    Information on any historic properties known to exist in the immediate area.
  • Summary of previous Section 106 Review(s) of the project, or an earlier project in the same location including dates of correspondence and project findings (if available).


  • U.S.G.S. topographic map or a formal city map clearly showing the project location and project boundaries and the project’s area of potential effects. Both U.S.G.S. maps and city maps are available on-line.  All associated project areas, such as borrow or disposal areas, should also be marked.  An 8.5" x 11"  photocopy of the relevant section of the map is preferred.  The name of the map and date should be provided on the photocopy.  Telephone book maps are not acceptable.
  • General photographs of the project area.  Photographs should include several views that show the surrounding area.  For all cell tower and wind farm projects, the photographs are to show several views to and from the proposed tower location(s). Please do not submit Polaroid photos or digital photos on disk or by email. 35mm film or digital prints are preferred.
  • Specific photographs of building elements that will be modified as part of the project. If the structure(s) to be affected is 45 years old or older, please submit an Idaho Historic Sites Inventory (IHSI) form or short form with accompanying maps and photographs.  Photographs should show each elevation of the building, oblique views, architectural details, and overall perspectives of the surrounding area.
  • Architectural plans, drawings, and elevations, as necessary, to describe the project.
  • Any correspondence with Tribes, city or county historic preservation commissions or historical societies, or other consulting parties.

Survey Reports

If an archaeological or historical survey has already been conducted, one copy of the report (and one copy of any site records) should be attached to the cover letter and sent to SHPO.  The cover letter may then provide only the Federal agency information and brief project description, as long as the rest of the information and attachments are provided in the archaeological or historical report.

SHPO Review

After receiving the project information described above, the SHPO will check the inventory and survey records to determine if surveys have been conducted and whether archaeological sites or historic buildings and structures have been previously identified within or adjacent to the project area.

SHPO Comment

Based on the nature of the project and on the project’s location, the SHPO will usually make one of the following comments. (The term “historic properties” includes both archaeological sites and historic buildings and structures.)

Additional project information is needed.

Considering the nature of the project and the project’s location, it is likely that historic properties are located within the project area that could be affected by the project.  The Federal agency (or applicant) should hire a professional archaeologist, historian, or architectural historian (as appropriate) to survey the project area and evaluate any archaeological sites or historic buildings or structures.  This work must follow the Secretary of the Interior’s Standards for Archaeology and Historic Preservation, and the professional conducting the work must meet the Secretary of Interior’s Professional Qualifications Standards.

No historic properties will be affected.  Either archaeological and/or historical surveys have been conducted, and no historic properties are located within the project area; or the project area has been surveyed, and historic properties have been recorded and evaluated for eligibility to the National Register of Historic Places.  Although sites exist within or adjacent to the project area, the project will not affect them; or considering the nature of the project and the project’s location, it is unlikely that the project will affect historic properties.

No adverse effect.  Historic properties may be affected.  The project should be changed (as recommended) to avoid effects on historic properties.  If the necessary changes are made, the project will have no adverse effect on historic properties.

Adverse effect.  Historic properties will be affected.  Additional consultation with the Idaho SHPO and the Advisory Council on Historic Preservation is necessary.  The Federal agency and the SHPO, and other consulting parties, as appropriate, will develop a Memorandum of Agreement (MOA) that stipulates mitigation measures.

Time Frames

The SHPO has 30 days to comment at each step of the review process.  If the SHPO receives sufficient information in the first project review package, many reviews will take only 30 days.  Otherwise, additional 30-day review periods will be required.

Record Keeping

The SHPO maintains the records and databases of all review information and site and survey reports.  However, it is very important that the agency or applicant keep their own records.