Key Resource: Cultural Resources and Historic Properties
Types of effects include loss of or damage to cultural resources and historic properties.
Cultural resources and historic properties are the physical evidence or places of past human activity that are significant representations of our nation's history. Disturbances to cultural resources and historic properties by modification, destruction, or changes to visual or physical settings can result in a compromise to their meaning and context. This chapter provides a description of known cultural resources and historic properties in the Study Area and identifies the potential for the No Action and Action Alternatives to affect these properties. The FRA also considered cultural resources and historic properties as part of the assessment of Visual and Aesthetic Resources (Chapter 7.10), Noise and Vibration (Chapter 7.12), and as part of the Section 4(f) evaluation (Chapter 7.16) of this Tier 1 Draft Environmental Impact Statement (Draft EIS).
For this Tier 1 Draft EIS, the FRA relies on the Advisory Council on Historic Preservation's (ACHP)1 and the Council of Environmental Quality (CEQ)2 definitions for historic properties and cultural resources. The ACHP defines historic properties as "a prehistoric or historic district, site, building, structure, or object included in or eligible for inclusion in the National Register of Historic Places. This term includes artifacts, records, and remains that are related to and located within these National Register properties. The term also includes properties of traditional religious and cultural importance to an Indian tribe or Native Hawaiian organization, so long as that property also meets the criteria for listing in the National Register."3 The CEQ and ACHP define cultural resources to include historic properties "as well as additional resources such as sacred sites, archaeological sites not eligible for the NRHP, and archaeological collections."4
The National Register of Historic Places (NRHP) is the official list of the nation's historic places worthy of preservation; it is authorized by the National Historic Preservation Act (NHPA) and maintained by the National Park Service (NPS). The NPS or the ACHP may designate the properties on the NRHP as traditional cultural properties. Tribal resources identified in the NPS 2010 database and the Housing and Urban Development (HUD) Tribal Directory Assessment Tool (TDAT) database have been included as part of this assessment. Some NRHP-listed properties have obtained the highest federal designation of historic significance. The NPS designates them additionally as National Historic Landmarks (NHL) because of their national importance. As a result, they require the most stringent consultation under Section 106 of the NHPA to resolve adverse effects.
For purposes of this Tier 1 analysis, the Federal Railroad Administration (FRA) did not evaluate cultural resources and historic properties that are only listed in or deemed eligible for listing in the state register of historic places (state register) or were recognized at the local level as important (county, city, village, or town).
Appendix E, Section E.09, contains additional information about data sources and resource assessment.
Section 106 of the NHPA requires federal agencies to take into account the effects of their undertakings on historic properties through a consultation process that includes a State Historic Preservation Officer (SHPO) and other parties. Regulations issued by the ACHP (36 CFR 800) outline the requirements for Section 106 consultation. The regulations define an "undertaking" to include "a project, activity, or program funded in whole or in part under the direct or indirect jurisdiction of a Federal agency, including those carried out by or on behalf of a Federal agency; those carried out with Federal financial assistance; and those requiring a Federal permit, license or approval."
The FRA has determined that the NEC FUTURE proposed action, the development and adoption of an investment program to improve passenger rail service on the NEC, is an undertaking with the potential to affect historic properties.5 Therefore, the FRA is conducting a Section 106 consultation process for NEC FUTURE concurrently with the National Environmental Policy Act process.
The Section 106 consultation process during Tier 1 has included consultation with the Federal Transit Administration (FTA), SHPOs,6 the ACHP, federally recognized tribes, and other consulting parties. This process has focused on identification of historic properties listed by the NRHP ("known historic resources") and identification of the types of potential effects on known historic resources that could occur as a result of Tier 2 undertakings. The FRA identified known historic resources within a preliminary area of potential effect (Preliminary APE), which is intended to include those resources that have the greatest potential to be affected by the Tier 1 Draft EIS Action Alternatives (see Section 7.9.3 for a description of the Preliminary APE). The FRA documented the results of this analysis in this chapter of the Tier 1 Draft EIS. More-detailed identification of historic properties, assessments of effects, and resolution of adverse effects will occur as part of Tier 2 undertakings for individual Tier 2 projects.
As part of Section 106 compliance for NEC FUTURE, the FRA has worked with the FTA, SHPOs, ACHP, tribes, and others to develop a Programmatic Agreement; the Programmatic Agreement, establishes the process that will be followed for Section 106 compliance during the environmental review process for Tier 2 projects. Appendix G provides the draft Programmatic Agreement for review and comment during the public comment period associated with this Tier 1 Draft EIS. Based on feedback received during the comment period, the FRA will revise and finalize the Programmatic Agreement for execution.
During Tier 2 studies for individual Tier 2 projects, the FRA (or another federal agency with Section 106 responsibilities for the particular Tier 2 project) will determine a project-specific APE and will complete the identification of historic properties, assessment of effects, and resolution of adverse effects for each Tier 2 undertaking. Consulting parties will be invited to participate in Section 106 consultation for individual Tier 2 projects, as appropriate, in accordance with the Section 106 regulations and the Programmatic Agreement.
The FRA undertook government-to-government consultation, in compliance with Section 106 of the NHPA, with federally recognized tribes identified having lands or resources in the Study Area. The FRA identified the following tribes:
The FRA contacted each tribe to initiate government-to-government consultation and subsequently invited each tribe to participate in the Section 106 process as consulting parties. In addition, the FRA identified the tribes known to have tribal lands or resources, or that claim ancestral lands or resources, in counties within the Study Area that are traversed by the No Action and Action Alternatives. The FRA specifically invited tribes within this smaller group (noted above in bold text) to be concurring parties to the NEC FUTURE Programmatic Agreement. As part of the government-to-government consultation, the FRA met with many of these tribes; the FRA regularly provided all tribes information about program updates via emails, letters, and meetings and by inviting the tribes to participate in public meetings and/or government-to-government consultations. (Appendix G provides a list of correspondence with tribes.).
The FRA developed an effects-assessment methodology to evaluate cultural resources and historic properties (see Appendix E, Section E.09). The effects-assessment methodology defines the resources and data sources, explains how the Preliminary APE was defined and established and how potential effects on each property were evaluated and reported. (Appendix E, Section E.09, provides data that supports the analysis presented in this chapter. Appendix A, Mapping Atlas, provides the general locations of cultural resources and historic properties associated with each Action Alternative.)
The assessment evaluated the presence of the following within the Study Area:.
The FRA collected data for each Action Alternative for the 1-mile-wide Preliminary APE to comply with Section 106 of the NHPA and 5-mile-wide Context Area, centered on the Representative Routes. Table 7.9-1 summarizes key factors associated with the effects-assessment methodology for cultural resources and historic properties.
The information available in this Tier 1 process allows for the identification of potential effects on known historic properties, but the assessment of effects at Tier 1 is constrained by (1) the limitations of existing records, which do not comprehensively identify all historic properties that may be eligible for listing in the NRHP; and (2) the level of detail known about the Action Alternatives, which are developed only at a conceptual level during Tier 1.
|Resource||Affected Environment (Preliminary APE)||Type of Assessment||Outcome|
|National Register of Historic Places (NRHP)-listed and National Historic Landmark (NHL)-listed properties and districts||1-mile-wide swath centered along Representative Route for each Action Alternative||
Implementation of the No Action and Action Alternatives could affect cultural resources and historic properties through physical disturbance or demolition of the property, through proximity effects such as noise and vibration, or through changes to the visual character or aesthetic qualities. The FRA identified numerous historic properties listed on the NRHP, some of which are designated as NHLs within the Study Area. The FRA specifically called out NHLs in this analysis because of their national importance, and they require the most stringent consultation under Section 106 of the NHPA to resolve adverse effects. Potential effects on NHLs are an important consideration in identifying a Preferred Alternative.
Cultural resources and historic properties are dispersed throughout the Study Area with higher numbers of NRHP properties and especially NHLs found in urban areas that were heavily populated during the colonial era (i.e., Washington, D.C., Philadelphia, New York City, Providence, and Boston). Typically, greater numbers of historic buildings and districts are associated with areas where the Action Alternatives are close to the existing NEC, or divert into new urban areas.
In addition, the FRA identified federally recognized tribes known to have tribal lands or resources, or that claim ancestral lands or resources, in counties within the Study Area. The FRA further identified those federally recognized tribes that claim ancestral lands or resources in counties traversed by the No Action and Action Alternatives. The FRA has identified tribal and ancestral lands in Suffolk County, NY; New London County, CT; and Washington County, RI. The FRA identified additional ancestral lands in all counties within the NEC FUTURE Study Area that are located Pennsylvania, New Jersey, New York, Connecticut, Rhode Island, and Massachusetts.
Key findings of this analysis are:
Most counties within the Preliminary APE for the No Action Alternative and each Action Alternative contain NRHP-listed cultural resources and historic properties; fewer contain NHLs. Table 7.9-2 summarizes the number of cultural resources and historic properties identified as occurring in the Affected Environment for the existing NEC and each Action Alternative. Cultural resources and historic properties are concentrated primarily in urban areas such as Washington, D.C.; Philadelphia, PA; New York City, NY; Hartford, CT; Providence, RI; and Boston, MA. Some of the NHLs identified include the United States Capitol (Washington, D.C.); New York Public Library, Empire State Building, Grand Central Terminal (New York City); the Florence Griswold Museum (Old Lyme, CT); Boston Public Library, Old South Church, Trinity Church, and the New England Conservatory of Music (Boston). (Appendix E, Section E.09, provides data for each state and county. Appendix A, Mapping Atlas, depicts property counts (NHLs and NRHP-listed properties) by county.)
(# of properties)
(# of properties)
(# of properties)
(# of properties)
A review of the HUD TDAT database and coordination identified counties where federally recognized tribes have claimed (or have indicated to the FRA) that they may have tribal resources within them. Table 7.9-3 provides a list of the federally recognized tribes and counties of interest by alternative. For any future Tier 2 activities that may occur within these counties, the lead federal agency would be required to further consult with identified tribes.
|MD||Prince George's||1, 2, 3||
|DE||New Castle||1, 2, 3||
|PA||Delaware||1, 2, 3||
|NJ||Mercer||1, 2, 3||
|NY||New York||1, 2, 3||
|CT||Fairfield||1, 2, 3||
|RI||Washington||1, 2, 3||
|Bristol||1, 2, 3||
As outlined in the effects-assessment methodology and draft Programmatic Agreement, the FRA has determined that for purposes of Section 106 compliance, the NEC FUTURE program is an undertaking with the potential to affect historic properties. The FRA has taken steps during the Tier 1 process to identify historic properties and assess potential effects on historic properties by:
This analysis does not include any findings regarding determination of effects for historic properties identified in the Preliminary APE. Determinations on effects on historic properties would be made as part of Tier 2 undertakings.
In this Tier 1 process, the FRA assessed potential effects on historic properties by using mapping overlays to identify historic properties location with the Representative Route of each Action Alternative. The FRA noted the properties identified within the Representative Routes as potential environmental "effects," since these properties would be expected to have a higher likelihood of being directly affected by the implementation of an Action Alternative during construction or through operations. Indirect effects on cultural resources and historic properties, caused by implementation of an Action Alternative, could occur outside the Representative Route and could include increased noise levels, increased vibration, changes to the visual setting, or changes to access. While no determinations have been made on the specific effects of proposed construction types on specific properties identified, the following general effects on cultural resources and historic properties could occur as a result of the various construction types and methods proposed for the Action Alternatives:
Temporary construction effects could occur during implementation of an Action Alternative, where access roads are created and at staging and lay-down areas. Impacts could include temporary contextual disturbance to existing NHLs and NRHP-listed resources, and direct physical disturbance to below-grade NHLs and NRHP-listed resources through grading, earth moving, compaction, and/or landscaping.
Table 7.9-4 presents the number of NHRP/NHL listed properties identified within the Representative Route of each Action Alternative. Table 7.9-5 provides the number of properties for each Alternative 3 route option. The FRA specifically called out NHLs in this analysis because of their national importance, and they require the most stringent consultation under Section 106 of the NHPA to resolve adverse effects. (Appendix E, Section E.09, contains relevant data for each county, and provides further qualitative highlights about those properties identified in this analysis as potentially affected.).
|Geography||Type||Existing NEC (# of properties)||Alternative 1 (# of properties)||Alternative 2 (# of properties)||Alternative 3 (# of properties)|
|Geography||Type||Existing NEC||Alternative 3|
|D.C. to NYC (# of properties)||New York City to Hartford||Hartford to Boston|
|via Central Connecticut (# of properties)||via Long Island (# of properties)||via Providence (# of properties)||via Worcester (# of properties)|
Through government-to-government consultations and review of the HUD TDAT database, the FRA identified no property-specific tribal resources. As noted in Table 7.9-3, the FRA identified several counties within the Study Area as having tribal resources. During government-to-government consultation, the tribes reiterated the importance of continuing coordination with them during subsequent Tier 2 studies to confirm locations of sacred lands. The tribes further indicated that it should not be assumed that future activities taking place within an existing transportation right-of-way would not encounter tribal resources. Their concern is that some of the existing transportation, communication, and utility rights-of-way were developed at a time that pre-date the more stringent environmental legislation and federal agency review processes in place today; therefore, undiscovered tribal resources may exist. During Tier 2 analysis, coordination with identified tribes would continue to confirm the absence or presence of tribal resources.
Some properties associated with the existing NEC rail infrastructure are listed in or are potentially eligible for listing in the NRHP; therefore, it is likely that with actions being undertaken as part of the No Action Alternative, cultural resources and historic properties could be affected either temporarily by construction activities or permanently.
Four NHLs lie within the Representative Route for Alternative 1: the Fairmount Waterworks and the Woodlands in Philadelphia; the historic estate of Andalusia in Bucks County, PA; and the College Hill Historic District in Providence, RI. Because the facilities and infrastructure proposed as part of Alternative 1 would be similar to the facilities and infrastructure present on the existing NEC, the FRA expects visual impacts to these properties to be minimal since changes to the appearance of the Representative Route are not expected.
Most properties are in urban locations such as Washington, D.C.; Baltimore, MD; Wilmington, DE; and Philadelphia. Additional areas of higher properties counts in Connecticut, Rhode Island, and Massachusetts result from prior NRHP listing or determinations of eligibility for railroad-related properties in these states as part of a prior Amtrak evaluation of properties in this corridor. There are 142 NRHP-listed properties associated with Alternative 1, including the Old Lyme Historic District in New London County, CT; the Rhode Island Statehouse in Providence, RI; and the South End District in Suffolk County, MA.
Five NHLs lie within the Representative Route for Alternative 2: the Fairmount Waterworks, the Woodlands, and the John Bartram House in Philadelphia; the historic estate of Andalusia in Bucks County, PA; and the College Hill Historic District in Providence, RI. The types of facilities and infrastructure that would be constructed near these NHLs would be the same as the NEC. The FRA expects visual impacts to these properties to be minimal, so changes to the appearance of the Representative Route are not expected, with the exception of the John Bartram House. Construction of infrastructure proposed under Alternative 2 near the John Bartram House would be on an embankment adjacent to Bartram Park surrounding the house. There are 171 NRHP-listed properties associated with this alternative, including Capitol Hill Historic District in Washington, D.C.; the Galloway Walker House in New Castle County, DE; and the Mid-Town Historic District in Union County, NJ.
The New Haven-Hartford-Providence new segment of Alternative 2 passes through the cities of New Haven and Hartford, and Tolland and Windham Counties, CT, each containing numerous identified properties. The FRA's coordination with the CT SHPO indicated that a Representative Route through Connecticut could encounter additional properties that have not yet been identified.
Washington, D.C., to New York City
Five NHLs lie within the Representative Route for Alternative 3 in the Washington, D.C., to New York City portion: the Fairmont Waterworks, the Washington Square West Historic District, the Woodlands, the Reading Terminal and Trainshed, and the historic estate of Andalusia (located in Philadelphia and Bucks County, Pennsylvania). The types of facilities and infrastructure constructed near Andalusia would be the same as the NEC, so visual impacts to these properties are not expected. Construction near the Reading Terminal and Trainshed and Washington Square West Historic District would be in a tunnel with minimal changes to those areas.
The 46-51 NRHP-listed properties include Woodwardville in Anne Arundel County, MD; the Philadelphia Naval Shipyard Historic District in Philadelphia; and the Grand Hotel in New York City.
New York City to Hartford
Via Central Connecticut
No NHLs exist within the Representative Route of this route option, but there are 36 NRHP-listed properties, including Southbury Historic District No. 1 in New Haven County, CT; and the Farmington Canal-New Haven and Northampton Canal in Hartford County, CT. Hartford County, CT, contains 18 properties (the highest number of properties of any county for this route option), mostly in the city of Hartford. Given the rural, undeveloped nature of the rest of Central Connecticut, the potential exists to encounter undiscovered cultural resources and historic properties along this route option.
Via Long Island
No NHLs exist within the Representative Route of this route option. There are 40 NRHP-listed properties associated with this route option include Prospect Cemetery in Queens County, NY, and the Bellarose Village Municipal Complex in Nassau County, NY. There are 16 properties in the Representative Route through Hartford County, CT (the highest number of properties of any county for this route option), mostly within the city of Hartford. The FRA's coordination with both the New York SHPO and Connecticut SHPO indicated that tunneling under the Long Island Sound could encounter archaeological sites and would require more-detailed investigations and field surveys were this route option to be advanced further.
Hartford to Boston
One NHL exists within the Representative Route of this route option: the College Hill Historic District in Providence, RI. There are 43 NRHP-listed properties in this Representative Route, including Pomfret Street Historic District in Windham County, CT, and Olmsted Park System in Norfolk County, MA, as well as the NRHP-eligible Waiting Room in the NRHP-listed South Station Headhouse in Suffolk County, MA. Providence County, RI, contains 18 properties, which is the highest number of properties of any county for this option. Within Providence County, properties include the NRHP-listed Central Street and College Hill Historic Districts.
One NHL lies within this option - the John B. Smith Building adjacent to Fenway Park in Boston. The Representative Route will be at-grade in this area and there is a potential for impact since it is adjacent to the property. Although the Representative Route passes through several historic districts in Hartford and Tolland Counties, CT; and Middlesex, Worcester, Norfolk, and Suffolk Counties, MA, virtually all contributing structures are outside, but near, the corridor. These districts include the NRHP-listed Blackstone Canal Historic District in Worcester County, MA, and the Newtonville Historic District in Middlesex County, MA.
The Action Alternatives include continued service to existing stations along the NEC, modifications to existing stations, which may require an increase in the station footprint, and new stations. Many of the existing stations along the NEC are themselves either NRHP-listed or NRHP-eligible.
Adverse effects may occur to historic properties where physical modifications are proposed, or to adjacent historic properties if there are changes in the setting caused by increases in the station footprint (i.e., expansion of or improvements to stations and associated facilities and amenities); such adverse effects could occur as part of implementation of an Action Alternative and would be assessed through the Tier 2 planning and Section 106 consultation process. Proposed new stations could result in adverse effects if they are located near NRHP-listed, NRHP-eligible, or NHL properties. Table 7.9-6 identifies which modified or new stations affect historic properties, by alternative and by station ID. Appendix E, Section E.09, provides detailed support data for Table 7.9-6.
Environmental Consequences for stations in each of the Action Alternatives would occur primarily from proposed modifications to existing stations. Many existing stations along the existing NEC are NRHP-listed or NRHP-eligible, meaning that physical changes to these stations in any of the Action Alternatives could result in an adverse effect. The construction of new stations would affect far fewer historic properties since the FRA proposed new stations in locations where fewer historic properties have been identified. Alternative 3 could have more station impacts than either Alternative 1 or 2, primarily in Baltimore City, MD; Philadelphia County, PA; Hartford County, CT; Worcester County, MA; and Suffolk County, MA, which would be caused by the modification of existing stations and the potential construction of new stations near existing cultural resources and historic properties.
|Geography||County||Station ID||Station Type||Station Name||Alt. 1||Alt. 2||Alt. 3|
|MD||Prince George's||4||Existing||Bowie State||X||X||X|
|10||Existing||Baltimore Penn Station||X||X||X|
|DE||New Castle||25||Existing||Churchman's Crossing||X||X||X|
|Philadelphia||45||Philadelphia 30th Street||X||X||X|
|46||Philadelphia Market East||X|
|Essex||74||Newark Penn Station||X||X||X|
|75||Newark Penn Station H.S.||X|
|NY||New York||77||Existing||Penn Station New York||X||X|
|New York||9993||Grand Central Terminal||X|
|111||New Haven Station||X||X||X|
|112||New||New Haven Station H.S.||X||X|
|113||Existing||New Haven State Street||X||X||X|
|New London||121||Existing||New London||X||X||X|
|124||New||Mystic/New London H.S.||X|
|129||New||Providence Station H.S.||X||X|
|142||New||Back Bay H.S.||X|
|143||Existing||Boston South Station||X||X||X|
There are numerous geographic areas in the Context Area where there are high densities of NRHP-listed properties and NHLs; these areas are mainly in urban locations. The number of properties in the 5-mile-wide Context Area outside of the Affected Environment is drastically greater than the number of properties identified in the narrower Affected Environment because of the drastically larger size of the Context Area. Table 7.9-7 identifies the total number of properties within the Context Area, with support data presented in Appendix E, Section E.09.
|Study Area||Alternative 1
(# properties, range)
|Context Area (excluding Affected Environment)||3,576||3,839||4,052-4,936|
NHLs within the Context Area are of particular concern because the NPA designates NHLs as nationally significant properties. As a result, they require the additional consultation under Section 106 of the NHPA to resolve adverse effects. Prominent NHLs in the Context Area for the various Action Alternatives include the following:
Potential mitigation strategies, or treatment measures developed as part of resolution of adverse effects during the Section 106 consultation process, are dependent upon the type of cultural resource or historic property affected and the type of impact(s). The draft Programmatic Agreement presented in Appendix G lists standard treatments, stipulations, and methods to resolve adverse effects. With respect to Tier 2 evaluations, the Programmatic Agreement lays out roles and responsibilities as well as guidance for Tier 2 project-level identification and evaluation of historic properties, and mitigation.
Some examples of measures to avoid, minimize, or mitigate adverse effects to cultural resources and historic properties include the following:
This Tier 1 analysis focuses on previously identified, or known, historic properties. During Tier 2 analysis, the lead federal agency for the Tier 2 undertaking would be responsible for continued Section 106 compliance and for defining a project-specific APE; cultural resources and historic properties identified as part of this Tier 1 Draft EIS would be analyzed in greater detail, and efforts to identify and evaluate additional properties within the Tier 2 project APE would be undertaken. In addition, resources of state and local importance would be identified. E For any future Tier 2 activities that may occur within counties noted as having tribal interests, the lead federal agency would be required to further consult with identified tribes.
Effects to the more thorough and complete listing of cultural resources and historic properties would be determined through field surveys as appropriate, and consultation with each relevant SHPO and/or tribe or THPO and local government. Counties of interest to the federally recognized tribes identified in Section 184.108.40.206 exist within the Study Area; therefore, any subsequent Tier 2 actions involving these counties would require the lead federal agency to consult with those tribes to confirm the absence or presence of tribal resources in relation to a proposed alignment or ancillary facility. Property-specific treatment measures and designs would be developed that would avoid, minimize, or mitigate adverse effects on cultural resources and historic properties. The analyses would comply with federal and state regulations identified in the state-specific appendices of the Programmatic Agreement (see Appendix G).
1 The Advisory Council on Historic Preservation is an independent federal agency that promotes the preservation, enhancement, and productive use of our nation's historic resources, and advises the President and Congress on national historic preservation policy. http://www.achp.gov/aboutachp.html
2 The Council on Environmental Quality (CEQ) coordinates federal environmental efforts and works closely with agencies and other White House offices in the development of environmental policies and initiatives. https://www.whitehouse.gov/administration/eop/ceq/
3 Advisory Council on Historic Preservation. (updated 2010). Protecting Historic Properties: A Citizen's Guide to Section 106, Advisory Council on Historic Preservation. Retrieved from http://www.achp.gov/docs/CitizenGuide.pdf
4 Council on Environmental Quality and Advisory Council on Historic Preservation. (March 2013). NEPA and NHPA, A Handbook for Integrating NEPA and Section 106. Retrieved from http://www.achp.gov/docs/NEPA_NHPA_Section_106_Handbook_Mar2013.pdf
5 This determination is based on FRA's role in sponsoring and funding the development of the Investment Program and the likelihood that decisions made by FRA as part of NEC FUTURE will be used to guide future federal funding decisions for projects on the NEC over a period of many years.
6 The consulting parties during Tier 1 included the SHPOs from the District of Columbia and the states of Maryland, Delaware, New Jersey, Pennsylvania, New York, Connecticut, Rhode Island, and Massachusetts.
7 The term eligible for inclusion in the National Register includes both properties formally determined as such in accordance with regulations of the Secretary of the Interior and all other properties that meet the National Register criteria. For purposes of NEC FUTURE, the FRA does not quantify NRHP-eligible resources with the exception of railroad-related properties previously identified by others and those specifically called out by SHPOs.
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