05/11/2013
It is my understanding that the “best practice” in professional heritage management and for lead government agencies is to use a 45 year old threshold to assess the eligibility of a structure. (In other words once the federal or state government establishes a higher level of practice, in may be considered poor practice, even malpractice, to practice at a lower level.) That the 45 year old threshold is the “best practice” is well-documented in the literature. A good example is “ADM 1020.2 Procedures for Historic Properties” prepared by the U.S. General Services Administration (2003:14 f):
“f. Age Threshold. National Register eligibility criteria generally require that a building be 50 years old before it can be considered eligible for listing. To take into account the length of GSA’s planning, design and construction process, a threshold of 45 years old has been established for assessing the eligibility of a building for listing in the National Register. The intent is to prevent project delays and increased design and construction costs due to new compliance requirements affecting a project already in development.”
I believe that SHPO will consider providing some type of preliminary determination of eligibly for a building 45 years old. They may ask one to wait generally, but if there is a threat of destruction to the building, this enhances the 45 year old threshold approach. Criterion C might be the simplest approach. Under Criterion C, I think it can be plausibly argued that a covered bridge would have achieved significance shortly after the year it was built.
There is also the exceptional significance also mentioned in “ADM 1020.2 Procedures for Historic Properties” prepared by the U.S. General Services Administration (2003:14 g), which may or may not apply in this case but is helpful to mention:
“g. Buildings under 45. Buildings under 45 years of age will be assessed according to the National Register criteria of exceptional significance, as detailed in National Register guidance on determining the eligibility of properties under 50 and GSA studies on Federal public buildings of the modern era.”
Contact with SHPO should be in writing; probably you have to prepare a draft report, perhaps a nomination, and send a formal letter requesting a determination response. The fact that the building is threatened would be the reason for the report. I think when SHPO is written too, the document has to have all the elevation photos, drawings, and arguments to sell them, otherwise with just a letter a secretary might answer it and not even tell SHPO that it is a covered bridge, just some bridge, someplace, not very old.
I think that a California covered bridge cited in books is a shoe in for the California National Register.
Cheers, Don
Donald Verwayen
Registered Professional Archaeologist
Cultural Resources Facility
Department of Anthropology
Humboldt State University
