In a message dated 6/21/2005 8:57:28 AM Mountain Daylight Time,
[log in to unmask] writes:

> But the question remains unanswered: Is a facadectomy or the act of
> facadism
> considered an adverse effect (impact) and subject to (lets assume this is a
> federal property, for giggles) to Section 106 or NEPA?
>

I would say no, for the regulations, largely, perhaps with some room for
exceptional circumstances, address the exterior of buildings.  I have dealt with
this to some extent.  There have been a number of eligible buildings for which
we did recordation of interiors as well as exteriors, but it was the exterior
that mattered in the eligibility determination.  The only time that one would
consider this an adverse effect is when the interior is considered a part of
the eligibility determination, which in our part of the world occurs sometimes,
but not a large percentage of the time.

Mike Polk
Sagebrush Consultants, L.L.C.
Ogden, Utah