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