
NHPA Section 106 Compliance Reviewer
Evaluate projects against NHPA Section 106 requirements and generate compliance documentation
What You Can Do
You can evaluate whether a project requires Section 106 review, determine the appropriate federal agency lead, define the Area of Potential Effects (APE), identify consulting parties, assess adverse effects to historic properties, and generate compliance documentation including MOAs and Programmatic Agreements. This skill helps you scope compliance packages, review existing Section 106 documents for completeness, and prepare for consultation with SHPOs, THPOs, and Indian tribes.
Features
Systematically define Areas of Potential Effects based on project scope, geography, and indirect impacts
Map required federal agencies, SHPOs, THPOs, tribes, and other stakeholders for your project context
Evaluate impacts to historic properties using ACHP criteria and determine mitigation adequacy
Determine if your project qualifies for categorical exclusions or requires full Section 106 review
Generate defensible Memoranda of Agreement and Programmatic Agreements tailored to project-specific conditions
Create Section 106 review packages that satisfy ACHP standards and agency-specific requirements
Develop consultation and coordination plans aligned with federal and state preservation protocols
Example Output
Example 1: APE Definition for Highway Widening Project
- Direct APE: 0.5-mile corridor plus 300-foot buffer for visual/auditory impacts
- Indirect APE: Adjacent historic district (1.2 miles) requiring viewshed analysis
- Recommendation: Phase I archaeological survey within defined APE
Example 2: Consulting Party List for Federal Grant Project
- Federal Lead Agency: HUD (Community Development Block Grant)
- SHPO: Massachusetts State Historic Preservation Office
- Tribes: Wampanoag Tribe of Gay Head (Aquinnah), Mashpee Wampanoag Tribe
- Other Parties: Local preservation commission, adjacent property owners
Example 3: Adverse Effects Determination
- Finding: Project will have adverse effect on 1851 mill building (contributing to historic district)
- Mitigation: Historic American Buildings Survey (HABS) documentation + design modifications to minimize visual intrusion
- Outcome: MOA developed with SHPO and tribal representatives
What's Included
- SKILL.md instruction file with Section 106 compliance methodology:
- APE Definition Checklist: guidance on direct, indirect, and cumulative effects analysis
- Consulting Party Matrix: templates for identifying federal agencies, SHPOs, THPOs, and tribes by jurisdiction
- Adverse Effects Assessment Framework: ACHP criteria application and mitigation evaluation templates
- MOA/PA Template: customizable agreement language for common project types and mitigation scenarios
Who It's For
- Heritage consultants managing Section 106 compliance for cultural resource projects
- Project managers coordinating federal permits and approvals requiring historic preservation review
- Architects and planners integrating NHPA compliance into design and development workflows
- State Historic Preservation Office (SHPO) staff reviewing agency Section 106 submissions
- Tribal Historic Preservation Officers (THPOs) evaluating impacts to historic properties and sacred sites
Best For
- Defining Areas of Potential Effects (APE) for federally funded or permitted projects
- Identifying consulting parties and designing stakeholder engagement strategies
- Assessing adverse effects to historic properties and evaluating mitigation measures
- Drafting Memoranda of Agreement (MOA) and Programmatic Agreements (PA)
- Reviewing existing Section 106 documents for regulatory completeness and defensibility







