Surveying in the West

The Section 106 Review Process and What You Need to Know

Jun 17, 2025

Keep your major development project on track and on budget

We’ve outlined the key steps and critical insights for the Section 106 review process – collaborating with you every step of the way to keep your project on track.

1. Initiate the process

  • Determine undertaking
  • Coordinate with other reviews
  • Identify State Historic Preservation Office (SHPO), Tribal Historic Preservation Office (THPO), Native Hawaiian Office (NHO), Tribes, and other parties
  • Plan to involve the public

Chronicle’s unique position as a cultural and heritage resources firm with national reach and local and regional expertise allows us to understand our clients’ specific project needs. This is critical to starting your project off right and navigating the review and compliance process in its earliest stages. Our experts have ample experience in project initiation, including desktop reviews and drafting agreement documents such as Programmatic Agreements (PAs) and Memorandas of Understanding (MOUs).

2. Identify historic properties

  • Determine area of potential effects (APE) and scope of effort
  • Make reasonable and good faith effort to identify
  • Determine National Register eligibility
  • Consult SHPO, THPO, NHO, Tribes, and other parties
  • Involve the public

Our offices nationwide have maintained a long-time regional and local presence, and our experts have identified and assessed the National Register eligibility of hundreds of thousands of diverse cultural resources. Not only do we possess years of relevant project experience, but we have sustained long-term, positive professional relationships with Tribes/THPOs/NHOs, SHPOs, and various consulting parties. These relationships help ensure an inclusive and comprehensive approach to moving your project forward.

3. Assess adverse effects

  • Apply criteria of adverse effects
  • Consult SHPO, THPO, NHO, Tribes, and other parties
  • Involve the public

Chronicle’s depth and breadth of experience, both at the local and national level, integrated project management, and collaborative and innovative approaches give our clients and project stakeholders a pathway toward a resolution to the process, even when reaching milestones is complex and challenging. Our teams have excavated hundreds of sites, drafted creative alternative mitigation strategies, and worked with agencies, Tribes, and HPOs to avoid significant resources.

4. Resolve adverse effects

  • Develop and consider alternatives or modifications to avoid, minimize, or mitigate adverse effects
  • Notify the Advisory Council on Historic Preservation
  • Consult SHPO, THPO, NHO, Tribes, and other parties
  • Involve the public

Need help with your next project?

Let’s talk Section 106 – reach out to us at info@chronicleheritage.com.