I-25 and Broadway Environmental Assessment Reevaluation – Section 106

Below is a notice that L/BCRNO received from CDOT on January 27, 2021

Hi there! 
You are receiving this letter since you are considered a consulting or interested party in the Section 106 of the National Historic Preservation Act Process for the above referenced project.  The purpose of the Section 106 process is to ensure that federally funded projects take into account the effects of their actions on properties of historic significance.  For more information on the Section 106 process, please go to this link: https://www.achp.gov/sites/default/files/documents/2019-04/CitizenGuide2015v4-spreads%20layout.pdf

CDOT is completing a reevaluation of the I-25 and Broadway Environmental Assessment completed in 2008, to complete the Broadway, Ohio and Wedge Ramp project, and other related improvements.  This email and enclosed materials only addresses National Register eligibility of resources located within the project’s identified Area of Potential Effects.   In all, 31 properties 45 years of age or older were located within the project’s Area of Potential Effects.  Intensive level survey forms and evaluations were prepared for 19 properties. 


An evaluation of project effects on historic properties will be provided to you SEPARATELY, and will address proposed mitigation and historical interpretation concepts related to impacts to the Denver Tramway Trolley line on South Broadway. 


A summary letter, survey report and survey forms on the 19 properties can be found at this location: 
https://drive.google.com/drive/folders/1Ul2w-enR7YN1fDj_JnvmwOMmMl7j5p_X?usp=sharing

Please review the materials, and if you would like to  provide comments, please do so within 30 calendar days, no  later than Friday, Feburary 26, 2021.  If we do not hear from you by that date, we will assume you have no concerns regarding CDOT’s findings. 

Please do not hesitate to let me know if you have questions or concerns.  

Thanks, Barbara
Barbara Stocklin-Steely, MS
Senior Historian, Region 1 Planning and Environmental

P (303) 757-9397
barbara.stocklin@state.co.us  |  www.codot.gov
2829 W. Howard Place, Denver, CO 80204

L/BCRNO response as of February 2, 2020

Brittany Spinner reached out to Barbara with some questions. Here is their Q & A:

Hi Brittany,
Happy February! To answer your questions, see information below.

Q: Could you please help me understand the next steps and what it means for the houses that were deemed worthy of historic landmark status? 

A: Section 106 of the National Historic Preservation Act of 1966 requires entities – such as Denver – who are using federal funds for a transportation project to first identify historically significant properties with the project’s area of impact (Step 1).  Secondly, Denver must evaluate and minimize any adverse effects to these properties caused by the planned project (Step 2).  The applicant for the federal funds – in this case Denver – works with CDOT to complete these evaluations.  They are then submitted to the State Historic Preservation Office (History Colorado) and to other consulting parties (neighborhood associations, local historic preservation groups, etc.) who may have an interest in the project. So in terms of where we are in the process for this project:

  • Step 1:  Identify historically significant properties.   The letter we sent out last week addresses Step 1 only.   Denver originally identified historically significant properties affected by the I-25 and Broadway interchange improvements in 2008, but the project was not fully implemented at that time due to funding constraints.  So now that 13 years have passed, federal regulations require that Denver updates its 2008 efforts to identify historically significant properties.  So, the question at hand for the State Historic Preservation  Office and consulting parties (including neighborhood associations) is: Do you agree that we identified all of the historically significant properties within the project’s area of impacts?   
  • Step 2:  Evaluate effects to historically significant properties.  This step is coming next!  What this basically means is that the project must try to avoid and/or minimize any “adverse” impacts to significant historic properties identified in Step 1- so the project should try to not demolish historically significant properties if possible, to not remove historic features of these properties like historic fences or sidewalks, etc.  This second step will be addressed in a separate letter sent to the State Historic Preservation Office and consulting parties later in February or March 2021.  You will be able to comment on this step as well – this will also include the “final” proposed concept for the historic interpretation/pedestrian walkway that was presented to the neighborhood in December. 

Q: For the properties that they found to be worthy of landmark status, does the formal review by NHPA protect those buildings since they have been “qualified”?   

A: Great question!  The short answer is NO.  The project identifies properties that “qualify” for historic designation, and these properties are treated like they are formally designated for the purpose of the Section 106 process related to a specific project only.  SO, in this case the federally funded Denver I25/Broadway project must try to avoid and/or minimize adverse impacts to historically significant properties.  But that is the extent of the protection.  The Section 106 process does not formally confer any formal local, state or national designation on these properties. The owners of properties that qualify for listing in the National Register under the Section 106 process are free to alter or tear down their properties as they see fit.  The only exception to this would be for properties that already had a formal local, state or national designation on their property before the Section 106 process began for a project – then those properties would be subject to the protections afforded by those specific designations. 

Q: If just this review by the NHPA allows protections of those properties, what are the next steps to ensure that any construction would be done in a way to protect those buildings?

A: Hopefully, I addressed this in my response to your first question.  We will send a separate letter – with project plan sheets and design information – evaluating the project’s impacts to historically significant properties.  The State Historic Preservation Office and consulting parties (including neighborhood associations) will be able to comment as to whether the project is adequately minimizing and avoiding adverse impacts to historically significant properties.  In some cases, a project will add special provisions to the plans to ensure that historic properties are not impacted during construction, such as notes for contractors to protect a historic fence or mature plantings in front of a historic house.  


Q: Since the area has been noted to have historically relevant properties, is there any chance for CDOT to re-review the project scope to limit some of the sidewalk cuts, and reconstruction to help protect these buildings further? 

A: If there are new sidewalk cuts in front of historically significant buildings, you could certainly comment on that as part of the second step of the process.  The second step will dig deeper into the project design and its impact on historically significant properties.   Denver is designing the project to meet city standards and design criteria, and all of the sidewalk related work is occurring within city right of way, with no new impacts on private property.  But there will be more information on that in the second submittal. 

Please feel free to reach out to me if you have further questions.  I am happy to talk to you on a “google meet” if you have more questions, or feel free to call my cell phone at 602-692-4722. 

Thanks!  Barbara

Update: February 4, 2021

We sent a letter to send out to our residents at 700 and 800 South Lincoln to notify them of this project. We have learned that Lincoln residents have the opportunity to provide input on some portions of the I-25/Broadway project.

Update: February 15, 2021

No residents at the 700 & 800 blocks of South Lincoln have communicated with us via email that they wish to seek Section 106 protections for their properties (if their properties had not already been identified).

One resident asked:

1) Do you know the timing of when the City of Denver will look to remove my home for the Project? 

2) Have there been any communications on how the City will go about taking one’s property?

Please attend our meeting February 17 to learn about the project and ask these questions. Additional ways to get involved are:

DOTI meeting February 24

You can also contact the Lucky District 7 office

Update: February 18, 2021

Last night in our RNO meeting, we learned more about the I-25/Broadway project. Segment 4 of the project (in which the 800 block of South Lincoln will be torn down) is unfunded at the moment, with no time certain.

The group on the call, which included residents at the 800 block of South Lincoln, voted to included the historical review about the homes at this block in the Section 106 letter back to CDOT. We reached out to all the property owners, and one confirmed to us that they would like to include additional historic review for their property. We will post a final version of this letter once it is written & submitted.

Update: February 25, 2021

The L/BCRNO comment letter has been submitted to Barbara Stocklin at CDOT.

Thank you, neighbors, residents, property owners, members, and Maggie at the Council District 7 office for your assistance, support, and collaboration on this project.

Update: May 19, 2021

Please review our response to CDOT here.