Overview
The Environmental Review Process
Consultation with Connecticut SHPO for an Environmental Review is initiated by uploading information through an online portal: https://conncris.ct.gov/pages/environmental-review. The portal will guide you through the process by asking a series of questions related to SHPO’s review authority, project scope, and existing conditions. SHPO’s ability to complete a timely project review largely depends on the quality of the materials submitted.
Why You Have Been Referred to SHPO
There are a variety of federal and state laws that require agencies to “stop, look, and listen” before making decisions that affect historic resources. To comply with these laws, agencies must collect information on how their decisions could potentially impact historic resources and, if feasible, consider ways to avoid or mitigate those effects. Legal references to legislation, regulation, and orders under which SHPO completes environmental reviews are compiled in the document titled State Historic Preservation Office (SHPO) Environmental Review Process: Legal References. General overviews for key legislation can be found here:
Section 106 of the National Historic Preservation Act: https://www.achp.gov/protecting-historic-properties/section-106-process/introduction-section-106
National Environmental Policy Act: https://www.epa.gov/nepa/what-national-environmental-policy-act
Connecticut Environmental Policy Act: https://portal.ct.gov/OPM/IGPP/ORG/CEPA/Overview-of-Connecticut-Environmental-Policy-Act
SHPO completes most of its regulatory responsibilities within the framework of Section 106 of the National Historic Preservation Act. This process is adopted for all environmental reviews completed by SHPO because the roles, responsibilities, and terms are well-defined in Section 106. As a result, following this process ensures consistency in evaluation, facilitates projects with multiple compliance responsibilities, and allows for future federal funding. For projects only receiving state funding, the differences primarily are related to identifying significant historic resources (Step 2) and in resolving project impacts (Step 4). Please see the documents for these steps for additional information. This diagram provides a general overview of the process.
WHAT to expect
The Environmental Review process does not determine a specific outcome but establishes a sequential process leading to a final decision. The vast majority of projects (85%) conclude after Step 2. For these projects, you can expect to receive a letter from SHPO stating that “no historic properties are affected” by the proposed activities. For projects that move on to Step 3, SHPO may ask for additional information to better understand the historic resources that are present or how the project may impact them. Most of these projects will conclude with a letter from SHPO stating that there is “no adverse effect.” Of the approximately 2500 projects reviewed by SHPO each year, less than 5% proceed to Step 4. These projects often involve several conversations with SHPO staff to minimize or mitigate the historic loss. Please see the individual documents for each of these steps for additional information.
WHO is responsible for compliance
For all state and federal laws that consider historic resources, the agency administering funding, permitting, or approvals is responsible for compliance. Although agencies may delegate the responsibility of consultation with SHPO to the applicant, the agency ultimately is responsible for ensuring compliance and considering the recommendations of SHPO. The role of SHPO is to review, comment, and consult. Our office provides formal letters of consultation that can be shared with the responsible agency, applicant, project consultant, project proponent, and/or members of the public that explains its decisions. We are here to assist with getting through the compliance process in a legally defensible manner.
WHEN will SHPO respond
SHPO reviews all projects on a first come, first served basis, and a letter of concurrence generally is completed within 30 days of initiating consultation, but actual response can be faster.
Occasionally, additional project information is required. Once a review request has been through the initial 30 day response period, additional information will be reviewed as soon as possible after its receipt.
HELP is here for you!
You may contact staff at any time if you have questions about submitting a project for review or for the status of your project review. This is the current staff conducting Environmental Reviews on behalf of SHPO:
Cory Atkinson, Archaeologist (BOEM, DEEP, HUD, USDA)
cory.atkinson@ct.gov, 860-500-2458
Catherine Labadia, Archaeologist & Deputy SHPO (DOT, FERC, NPS, USACE)
catherine.labadia@ct.gov, 860-500-2329
Todd Levine, Architectural Historian (DOH, HUD, Lead Mandate, DECD, EPA, OPM)
todd.levine@ct,gov, 860-500-2337
Marena Wisniewski, Architectural Historian (HUD, DOH, Lead Mandate, CSC, DECD, EPA, FCC, OPM)
marena.wisniewski@ct,gov, 860-500-2357
For technical assistance with the Environmental Review system:
Kevin Berger, GIS Analysist, kevin.berger@ct.gov, 860-500-2355