BUREAU OF RECLAMATION
Lower Colorado Region

ADMINISTRATIVE DRAFT

Environmental Assessment
and
FINDING OF NO SIGNIFICANT IMPACT
(FONSI)

Citizens Congressional Task Force on the New River
Brawley Constructed Wetlands Demonstration Project


Small Reclamation Projects Act of 1956 Loan
(P.L. 84-984 as amended)
Salton Sea Reclamation Act of 1998
(P.L. 105-372, as amended)
IV. Consultation and Coordination

A. Persons and Agencies Consulted

Recommended:__________________________ Date:
Preparer, Environmental Protection Specialist


Concur:________________________________ Date:
Manager, Environmental Compliance and Realty Group


Approved:______________________________ Date:
Office Director, Resource Management and Technical Services


FONSI Number:____________ Date: March 19, 2001

PROPOSED ACTION TITLE: Brawley Constructed Wetlands Demonstration Project.

LOCATION OF PROPOSED ACTION: On the New River near Brawley and Imperial CA.
Brawley Site: Township 14 South, Range 14 East, Portion of Tract 199
Rice 3 Drain Site: Township 15 South, Range 13 East, Portions of Section 4 and 5

APPLICANTS: The Citizens Congressional Task Force on the New River (Task Force). Reclamation is a project proponent within the Task Force.

I. Need for Proposed Action

The New River has been recognized for many years as a river in need of help. The river is a tributary of the Salton Sea (Sea), located in the southern tip of California and occupying the northern part of the Salton Trough. The Sea is bordered on the northwest by the San Gorgonio pass, on the west by the San Jacinto and Santa Rosa Mountains and the Peninsular Range of Baja California and southern California, and on the east by the Little San Bernardino and Chocolate Mountains. On the south it is contiguous with the Imperial Valley through which the New River flows from Mexico and into the United States.

The focus of this study is to demonstrate the effectiveness of using constructed wetlands to improve water quality in the Imperial Valley, specifically on the New River. The Imperial Irrigation District (IID) provides agricultural and domestic water via the All American Canal to approximately 500,000 acres of farmland in the Imperial Valley. The Imperial Valley, in Mexico, maintains about 300,000 acres of irrigated and drained farmland where irrigation water is obtained by well fields in Mexico and gravity flow of Colorado River water delivered via the New Alamo Canal. A network of canals supply water throughout the Valleys. Drains at depths of 6 to 10 feet below surface called tile drains, carry drainage water containing dissolved salts to sumps or gravity tiles. These outlets are located at the lower end of the agricultural fields and discharge directly to surface drains (drainage ditches), these in turn drain to either the New River or directly to the Sea.

As a terminal lake, the Sea would have evaporated had it not been for agricultural drainage providing the inflows that sustain the Sea to this day. The Sea and its tributaries, the Alamo River, Whitewater River and New River, have provided opportunities for recreation, development, and fish and wildlife use in an otherwise inhospitable environment. Within the Sea area are located a California state park and a wildlife reserve for migratory waterfowl. However, as nutrients provided by agricultural flows from the surrounding farmland have caused eutrophic conditions, and as salinity has increased, the original recreational attraction faded and the Sea has become less desirable as wildlife habitat. Recent water supply demands and promulgation of agricultural water quality objectives have created pressure to alter the amount and the quality of water draining into the Sea through its tributaries. Changes made in response to this pressure could accelerate the decline of the Sea and seriously affect the surrounding area’s water quality. The members of the Task Force, Federal agencies, and several local entities recognized the resource potential provided by the Sea and formed the Task Force to address these issues. Current salinity levels in the Sea are around 44,000 ppm. Ocean water salinity is around 35,000 ppm.

The Task Force is proposing to construct two demonstration research wetlands on separate sites, both located in the Imperial Valley of Southern California, that will require federal permits and regulatory approvals from the Bureau of Reclamation (Reclamation), Environmental Protection Agency, and Army Corps of Engineers. Under the National Environmental Policy Act (NEPA) and the Council on Environmental Quality regulations for implementing NEPA, Reclamation was designated as lead Federal Agency and the Task Force designated as the Applicant for the proposed Brawley Wetlands Demonstration Project. The other federal agencies listed above are cooperators along with California Regional Water Quality Control Board, California Fish and Game, Office of US Congressman Hunter, Salton Sea National Wildlife Refuge, Imperial Irrigation District, and Imperial County. As lead federal agency, Reclamation has oversight responsibilities for managing the NEPA process, compliance documentation and agency coordination to be prepared for the proposed project. The Task Force is the applicant and will be funding the proposed project. Reclamation is participating in accordance with P.L. 105-372.

II. Description of Proposed Action and Alternatives
A. Proposed Action:

The purpose of these two pilot wetlands is not to create wildlife habitat but to demonstrate the ability of constructed wetland technology to improve the water quality of the New River. Water sources for the research wetlands include agricultural drain water for the Rice 3 Drain wetland site and New River water for the smaller Brawley wetland site. Wetland-processed water leaving both sites will eventually be returned to the New River.

The data on the effects of the wetland would be collected as discussed in the monitoring and operation plan (see attached Monitoring and Operation Plan, Attachment 4). This information will indicate how effective constructed wetlands are at removing contaminants in the New River and what factors are critical to full time operation of a constructed wetland under those conditions.

The proposed 7-acre site is adjacent to the New River near Brawley, CA. (See conceptual drawings and site maps, Attachment 1) The site is located among active agricultural fields with the closest building located 1/4 mile from the proposed site. The design for the constructed wetland encompasses the entire 7 acres and will consist of approximately five wet acres. Water will be pumped out of the New River and onto the site where it will flow through the wetland and then returned to the river. The site is owned by Imperial County and has been cultivated for at least 20 years. Vegetation on the site consists of a perimeter of mostly saltcedar. (See Biological Report, Attachment 2) (contact: Imperial County, Randy Reister 760-339- 4384).

The second site is located on 68 acres adjacent to the New River near Imperial, CA. (see Attachment 3) This site is also located adjacent to active agricultural fields and the closest building is 1/4 mile from the proposed site. The created demonstration wetland will use the entire 68 acres and will contain approximately 40 wet acres. This wetlands will use agricultural drain water from IID’s Rice #3 drain that flows into the New River. After flowing through the wetland, the water will be returned to the New River. Scrub vegetation (salt cedar) on the site has been bladed on a regular basis but the site has never been cultivated. The site is located between a 70-foot high bluff, the Rice #3 agricultural drain and the New River. The property is owned by Imperial Irrigation District (contact: IID, Paul Peschel 760-339-9256).
Water sources for the proposed research wetlands include agricultural drain water for the larger (68-acre) Rice 3 Drain wetland site and New River water for the smaller (7-acre) Brawley wet land site. Wetland-processed water leaving both sites will eventually be returned to the New River.

Both IID and Imperial County are members of the steering committee for this study and have donated the land for use to construct the two wetlands. An Initial Study was done by Reclamation and prior California Environmental Quality Act documentation for a similar pro ject was finalized on September 1, 1995 for the Rice 3 Drain site along with several other sites. CEQA documentation is included as Attachment 3.
B. No Action

Under the No Action alternative, Reclamation would not participate in the project. Based on the legislation, no other federal agency is tasked with taking action on this project. Therefore, there would be no action taken.

C. Alternatives Considered but Eliminated from Detailed Analysis.

A few other sites were considered for the project location, however, the two pro posed sites are the only ones that meet the project criteria. The following table lists the project screening criteria used to determine the suitability of sites.
Criteria

1. Immediate Access to Source Water

2. Exiting Support Roads

3. Zero Impact to Cultural/ Archeological

4. Minimal Impact to Endangered Species

5. Zero legal entanglements

6. Zero Acquisition Cost

7. Acreage must be sufficient for research objective.

Description

To keep operation and maintenance costs to a minimum, gravity flow into the wetland cells is essen tial. This is only possible immediately adjacent to the water source.

The amount of equipment used in construction and operation of the facilities requires road access. Construction of roads would be prohibitively expensive.

Given the nature of construction and operation any cultural landmarks would be destroyed and archeological findings would result in a prohibitive delay.

The nature of the project makes it attractive towildlife in the area, some of it endangered. This effect must be minimal and positive.

Any prolonged legal proceedings to gain access or acquisition would result in a prohibitive delay and cost.

Due to the small budget of the project. Any land considered for use in the project must be donated.

The purpose is to test wetland technology on New River Water. To scale the project footprint down to a total area smaller than 70 acres wold render the results from the research inconclusive.
Alternate Sites:

Alternate locations for the project are limited to surrounding available agricultur al land being worked in the Imperial Valley. An alternative site for the Rice 3 Drain site is on the over-looking bluff to the south. Approximately 70 acres of production farmland is needed for the project. Although it would be located above the flood plain, acquisition of the land was abandoned when the IID parcel became available because of the prohibitive development and operation costs, and poor access to source water. Most of the development costs would be in acquiring the land and pipeline right-of -way from the private owners and build ing the additional piping and pumps to get the source water to the wetland. Increases in operation costs would be for lifting the water and maintenance of a much more complicated system. Use of this site would eliminate the project.

An alternative location for the smaller wetland above the flood plain is on a bluff southeast of the proposed Brawley site. This site suffers from the same ills as the alternative for the larger wetland - poor access to source water and prohibitive development/operating costs.
III. Environmental Impacts

The following critical elements of the human environment are, with few exceptions, either not present would be unaffected by the proposed action or alternatives. The affected categories of T&E Species, Water Quality and Wetland and Riparian Resources are discussed in following the list of elements.
Critical Element Affected Critical Element Affected
Yes
/No
Yes
/No
Air Quality / XX T & E Species XX/
Cultural Resources / XX Wastes, Hazard/Solid / XX
Environmental Justice / XX Water Quality XX/
Farmlds, Prime/Unique / XX Wetlands/Ripar. Zns / XX
Floodplains / XX Wild & Scenic Rivers / XX
Indian Sacred Sites / XX Indian Trust Assets / XX
A. Proposed Action

Environmental Compliance

Informal consultation with the Fish and Wildlife Service (Service) was initiated and continues for the proposed project pursuant to section 7 (a) and (c) of Endangered Species Act (ESA). Because of FWS representation on the Task Force, informal consul tation was initiated when the Task Force first convened. Consultation is supported with a Negative Declaration completed by Imperial Irrigation District (1995) and a follow-up Biological Report (1998) (BR) prepared by Reclamation. Based on the review of avail able documentation and findings in the BR, Reclamation notified the Service that the proposed project was "Not Likely to Adversely Affect" listed species or their designated critical habitat. The "Not Likely to Adversely Affect" determination and notification commenced the formal consultation under ESA. An Interagency Agreement for completion of the Coordination Act Report was drafted and sent to Fish and Wildlife Service.

The Department of Interior policy (Secretary of the Interior Order 3175) requires that actions under NEPA consider potential effects on Indian Trust Assets (ITAs). Reclamation policy is to protect ITAs from adverse impacts of its programs and activities when possible. Indian trust assets are property interests held in trust by the Federal government for the benefit of Indian tribes or individuals. Courts have traditionally interpreted them as being tied to property. Lands, mineral rights, and water rights are common examples of ITAS. There are no Federally recognized Indian tribes or tribal lands in the project area, and thus there will be no impacts on ITAS.

Executive Order 12898 and Reclamation Policy (PEP-No. ECM 95-3) requires that all NEPA documents consider the impacts of Federal actions on minority and low-income populations and communities, as well as the equity of the distribution of benefits and risks of those decisions. To comply with Environmental Justice Policy, NEPA docu ments should identify and evaluate any anticipated effects, direct or indirect, from the proposed project, action, or decision. No minority and/or low-income populations and communities are located in the proposed project area. Thus no impacts to minority and/or low-income populations and communities will occur as a result of the construction and operation of the proposed project.

Executive Order 13007 requires Reclamation, to the extent practicable, permitted by law, and not clearly inconsistent with essential agency functions, to avoid adversely affecting the physical integrity of Indian sacred sites and to allow access by Indian religious practitioners to such sacred sites. The sites are agricultural and one has been in production for the past twenty years. Both sites were evaluated by Reclamation archeologists and neither site is owned by a tribe. Thus no impacts to Indian sacred sites and no interference with Indian religious practices will occur as a result of the construction and operation of the proposed project.

In accordance with NEPA and the Council on Environmental Quality Regulations for Implementing the Procedural Provisions of NEPA, Reclamation has determined, that with implementation of the environmental mitigation commitments in the project EA and those listed below, that the agency proposed action, construction and operation of the proposed Brawley Constructed Wetlands Demonstration Project, will not significantly affect the quality of the human environment. Since there will be no significant impacts on the human environment from the proposed project, it is recommended that this FONSI be approved for the approval of financial support for the Brawley Constructed Wetlands Demonstration Project. An environmental impact statement will not be prepared.
1. Threatened and Endangered Species
U.S. Fish and Wildlife Service (FWS) was contacted on Jul 21, 1998 by Reclamation to provide a list of potential Threatened and Endangered Species for the proposed project in accordance with Section 7(a) of the Endangered act of 1973. Their memorandum of Sep 8, 1998 provided a list of seven Endangered, Threatened, Proposed, and Candidate species (T&E) and 31 Sensitive species that may occur in the study area. (See Attachment 5, Section 7 Consultation Documentation)

Habitat and presence of the seven listed species were assessed in the Biological Report (Report, Jan 1999). (See Attachment 2) Based on the findings in the Report, Reclamation sent a memorandum dated 3/5/99, to FWS stating that Reclamation has determined that the project is "not likely to adversely effect" any listed species based on the lack of listed species or suitable habitat in the project area, and the project’s poten tially beneficial effects.
2. Water Quality
The purpose of the project is to study how wetlands can improve water quality in the New River and inflows to the Salton Sea. Indications are that benefits from this research would be the reduction of contaminates found in agricultural drainage water.

The Army Corps of Engineers (COE) has determined that this project did not come under the jurisdiction of Section 404 of the Clean Water Act. Because of this, the COE stated that a 404 Permit was not required.

Because of the exemption provided by Congress, and in consultation with the USEPA, the California Regional Water Quality Control Board determined that this project did not require a National Pollution Discharge Elimination System (NPDES) permit.
3. Wetlands/Riparian Zones
Success in demonstration of the wetlands to improve water quality could slow the decline of the Sea as a wildlife refuge. This, in turn, could result in creation of additional high quality wetland wildlife habitat.
B. No Action
Under the No Action alternative, there would be no direct impacts to T & E species, wetlands, riparian zones, and water quality. An opportunity would be lost to demon strate the feasibility of using wetlands to improve water quality and potentially create additional high quality wetland habitat.

No action will result in the New River water remaining at its current poor quality. Further deterioration of the Salton Sea is also expected based on current use of the New River. If current water use practices are continued, eutrophic conditions in the Sea will prevail.
C. Cumulative Impacts
Cumulative impacts on water quality were considered for Threatened and Endangered Species, Water Quality and Wetlands/Riparian Zones and for a planning horizon of ten years. Although the concept of using wetlands could improve water quality within the Sea, the cumulative effects of this specific project are discountable or insignificant with in the planning horizon for a two mile area surrounding the two wetland sites. Should the use of wetlands on the New River prove a success, then use of project findings to construct other wetlands on the New River and Alamo River would have the cumulative effect of slowing or stopping the decline of water quality. It could also improve the existing wetland and riparian areas and would most likely aid in the creation of new riparian habitat.
D. Environmental Mitigation Commitments
The following environmental mitigation commitments shall become a condition of approval.

Permits: The Task Force will obtain all necessary permits and will comply with all applicable Federal, State, and local regulations related to the environment. Copies of all permits will be provided to Reclamation for inclusion in the project file.

Cultural Resources: The State Historic Preservation Office (SHPO) was consulted and provided mitigation comments. Specifically, SHPO requested that IID will provide a trained person to be on site during the excavation phase of this project. Therefore, a qualified archaeologist and a Native American consultant shall monitor construction activities as they pass through either the Brawley site or the Imperial site. A qualified archaeologist shall monitor construction activities as they pass through or adjacent to the proposed sites. All of the identified sites have the potential for the discovery of buried cultural resources. The Task Force shall contract with a qualified archaeologist to implement the monitoring commitment and shall require the archaeologist to coordi nate this work with Reclamation. The Task Force and archaeologist shall submit a letter report to Reclamation on the results of the field monitoring of the noted archaeological sites.

Should cultural resources be discovered during construction, all ground disturbing activ ities in the area of the archeological resource will stop and Reclamation's Regional Archeologist will be contacted at 702-293-8705. Reclamation's compliance coordinator will also be contacted at 702--293-8519. Construction will not resume until all mitiga tive measures developed in consultation with the State Historic Preservation officer have been completed.

Riparian Habitat: Anticipated impacts from outfall construction at either site is not likely to result in damage to habitat. Should construction damage result in the removal of any mature willows or poplars the Task Force shall replace each removed tree with three 5-gallon specimens of the same species. This is a 3 to 1 replacement ratio for wil low and poplar trees. Although the estimate removal for this project is zero, any trees removed above this estimate shall be replaced, by type and number, following the above size and ratio criteria.

Threatened and Endangered Species: U.S. Fish and Wildlife Service (FWS) was con tacted on Jul 21, 1998 by Reclamation to provide a list of potential Threatened and Endangered Species for the proposed project in accordance with Section 7(a) of the Endangered act of 1973. Their memorandum of Sep 8, 1998 provided a list of seven Endangered, Threatened, Proposed, and Candidate species (T&E) and 31 Sensitive species that may occur in the study area. (See Attachment 5, Section 7 Consultation Documentation)

Habitat and presence of the seven listed species were assessed in the Biological Report (Report, Jan 1999). (See Attachment 2) Based on the findings in the Report, Reclamation sent a memorandum dated 3/5/99, to FWS stating that Reclamation has determined that the project is "not likely to adversely effect" any listed species based on the lack of listed species or suitable habitat in the project area, and the project’s poten tially beneficial effects. No mitigation for listed species is required for this project at either site.

A representative from the US Fish and Wildlife Service (FWS) has actively participated on the Task Force during the review of the conceptual wetlands design and preparation of the wetlands water quality monitoring plan. The plan includes sampling of sediment, tissue as well as water quality parameters.

Additional mitigation may be requires from the USFWS pending completion of the Fish and Wildlife Service Coordination Act Report.
E. Finding:
Based on the information contained in this Environmental Assesment, the Biological Report and other attached documentation, the Brawley Wetlands Demonstration Project will have no significant impact to the environment. Any impacts to the environment resulting from actions taken under this project will most likely result in improved habi tat and water quality for the affected area.
IV. Consultation and Coordination

A. Persons and Agencies Consulted

Members of The Citizens Congressional Task Force on the New River
NAME AGENCY / ADDRESS PHONE No FAX No.
Clark Bloom California State Parks
906 W. Sinclair Rd., Calipatria, CA
760-348-5278 348-7245
Robertta Burns Imperial County
940 W. Main, Suite 208, El Centro, CA 92243
760-339-4290 352-8786
Larry Caffey Fish and Game Commission
Chairman 940 W. Main Street, El Centro, CA 92243
760-337-4425
Nancy Andrew California Fish & Game
PO Box 1347, Brawley, CA 92227
760-351-1676
Jose Angel California Regional Water Quality Control Board
73720 Fred Waring Drive 3100,
Palm Desert CA 92260
760-346-7495 341-6820
Phil Gruenberg California Regional Water Quality Control Board
73720 Fred Waring Drive 3100,
Palm Desert CA 92260
760-346-7495 341-6820
Tom DuBose Lyon Engineering
1122 State Street, El Centro, CA 92243
760-353-8110 352-6408
Rob Zimmer Imperial County,
760 W. Main Street, El Centro, CA 92243
760-353-7000 353-6956
Tom Veysey Imperial County,
940 W. Main Street, El Centro, CA 92243
760-344-2121 344-2194
Wayne J. VanDeGraff Imperial County,
940 W. Main Street, El Centro, CA 92243
760-357-3030 352-7876
Stephen L. Birdsall Imperial County Agricultural Commission
150 South Ninth St., El Centro, CA 92243
760-339-4314 353-9420
Randy Rister Imperial County, Property Services Dept.
1002 State Street, El Centro, CA 92243
339-4372
Alec Rosenberg Imperial Valley Press,
PO Box 2770, El Centro, CA 92244
760-337-3453 353-3003
Mike Richmond District Director, US Senator Diane Feinstein
750 "B" Street, Suite 1030, San Diego, CA 92101
Cato Cedillo Office of US Congressman Hunter,
366 So. Pierce St., El Cajon, CA 92020
800-365-4545 619-579-2251
Roy Schroeder US Geologic Service,
5735 Kearny Villa Rd., San Diego, CA 92023
619-637-6824 637-6824
Jim Battin Assemblyman, Eighteenth District
1101 Airport Drive, Suite J, Imperial CA 92251
760-355-1295 355-1295
Carol A. Roberts
Biologist
Fish & Wildlife Service, Carlsbad Field Office,
2730 Loker Avenue West, Carlsbad, CA 92008
760-431-9440 431-9648
Ken Strum Salton Sea National Wildlife Refuge
906 West Sinclair RD, Calipatria, CA 92233
760 348 5278 348-7248
Curt Tauscher CA Fish & Game,
330 Golden Shore, Suite 50, Long Beach, CA 90802
562-590-5113 590-5871
Eugenia McNaughton EPA, WTR-4,
75 Hawthorne Street, San Francisco, CA 94105
415-744-1162 744-1362
Leon Lesicka Desert Wildlife Unlimited,
4780 Highway 111, Brawley, CA 92227
760-344-7073 344-4076
John Letey University of California,
Center for Water and Wildlife Restoration(?)
Riverside, CA 92521-0424
909-787-4327 787-3993
787-5105
Chris Amrhein University of California, Riverside,
Dept. of Soils and Environmental Science
Riverside, CA 92521-0424
909 787 5196 787-3993
Carl Bell University of California
1050 E. Holton Road,, Coop Ext. , Holtville, CA 92250
760-352-9474 352-0846
Dr. Les Young California Polytechnical University
3801 W. Temple Avenue, Pamona, CA 91768
909-869-2180 869-4454
Steve Muth Bureau of Reclamation
PO Box 61470, Boulder City, NV 89006-1470
702-293-8119 293-8146
John Pattie Bureau of Reclamation
P O Box 25007, D 8120, Denver, CO 80225-0007
303 445 3273 445-6489
Jim Setmire Bureau of Reclamation
PO Box 849, Temecula, CA 92590-2628
909-695-5310 695-5319
Jenny Synder Imperial Irrigation District
PO Box 937, Imperial, CA 92251
760 339 9382 339-3399
Michel Remington Imperial Irrigation District,
PO Box 937, Imperial, CA 92251
760-339-9149 339-9191
Steve Knell Imperial Irrigation District,
PO Box 937, Imperial, CA 92251
760-339-9256 339-9262
Tom Wolfe Imperial County Health Service
939 Main St., El Centro, CA 92243
760 339 4203 352-1309
Marie Barrett Imperial College
2035 Forrester RD, El Centro, CA 92243
760 355 6488 353-0465
Terry Dean US Army Corps of Engineers,
Regulation Branch
10845 Rancho Bernardo Rd., San Diego, Ca 92127 -2107
619 674 5386 674-5388
Jurg Heuberger Imperial County Planning,
939 Main Street, Fleet Building, El Centro, CA 92243
760-339-4239 353-8338
Robert Mclean National Wildlife Health Center
606 Schroeder, Greenfield, WI 53711- 6223
608 270 2401 270-2415
Mary Kay Borchard 427 Terrace Circle, Brawley,, CA 92227
Mark Johnson 939 Main St., El Centro , CA 92243
760-355-6279 355-2663
Carole Starr 1101 Airport Rd., Suite G,
Imperial, CA 92251
760-353-0653
Susan Manger 940 W. Main Street,
El Centro, CA 92243
760-339-4740 352-7876
B. Scoping and Public Involvement

Meetings are held with the Task Force on a monthly basis. These meetings are conducted in a public forum with invitations for questions. Distribution of the final draft Environmental Assessment, after review by the Task Force, will be to public libraries in Brawley and El Centro for public comment. Notification of availability will be in the local newspapers of those municipalities with an appeal to the publication to write accompanying articles to explain details of the project.

C. List of Preparers

Bureau of Reclamation

Dave Curtis, Environmental Protection Specialist
Pat Green, Environmental Protection Specialist
Dawna Ferris, Archeologist
Glen Gould, Fisheries Biologist
Barbara Raulston, Wildlife Biologist
Hank Kaplan, Biologist
Steve Muth, Biologist
John Palte, Design Architect
Attachment 1

Conceptual Drawings and Site Maps

Attachment 2

Biological Report.

Attachment 3

IID Negative Declaration

Attachment 4

NPDES Correspondence
w/Monitoring and Operation Plan

Attachment 5

Section 7 Correspondence
(Endangered Species Act)

Attachment 6

Section 106 Correspondence
(National Historic Preservation Act)