This really poses a fascinating problem. As the archeologist in charge of
managing sites in a large historic district (two architects and our cultural
resources manager handle the buildings), I forsee real problems with this
nomination. The first is the nomination process itself. One wonders whether
the GSA has fully realized the difficulty of nominating a district these
days. They might well be better off nominating individual properties before
a transfer. Documenting the entire district to modern nomination standards
is a major investment in time and money. (Not to mention the lengthy review
process associated with nominations).The second is the problem of
transferring property to a non-federal entity under the new Section 106
process which requires covenanting of the properties. This could be a longer
process than the former as the consultations progress. Of course, they could
look into making it a landmark, sending it to the NPS, and let Congress deal
with the problem.

John H. Dendy
Archeologist
Dynamac Corporation
Fort Reiley, KS