Federal Deposit
Insurance Corporation

From: moorele@cox.net
Sent: Thursday, December 01, 2005 12:54 PM
To: Comments
Subject: SOP - Regarding the National Historic Preservation

I think you should pay closer attention to the requirements of 36CFR800.

Covered applications may inadvertently be impacting historic properties, especially in old downtown areas where banking facilities are likely to be placed in old buildings. The last thing I would like to see is a new ATM machine placed on the façade of a building next to a plaque that states that the building is on the National Register of Historic Places.

While this SOP is about applications for deposit insurance I hope FDIC’s real estate transaction are also compliant to Section 106 of the NHPA. The following Executive Orders are relevant:

EO 11593 - Protection and Enhancement of the Cultural Environment

This Executive Order of 1971 requires federal agencies to administer cultural properties under their control, and to direct their policies, plans, and programs in such a way that federally-owned sites, structures, and objects of historical, architectural, or archaeological significance are preserved, restored, and maintained. To achieve this goal, federal agencies must locate, inventory, and nominate to the National Register of Historic Places (NRHP) all properties under their jurisdiction or control that appear to qualify for listing in the NRHP. The courts have held that the Executive Order obligates agencies to conduct adequate surveys to locate "any" and "all" sites of historic value.

This Executive Order also directs agencies to reconsider any plans to transfer, sell, demolish, or substantially alter any property determined to be eligible for listing in the NRHP and to afford the ACHP an opportunity to comment on any such proposal.

EO 13006 - Locating Federal Facilities on Historic Properties in Our Nation's Central Cities This Order requires all Federal agencies, in making decisions concerning locating their facilities, to consider the use and maintenance of historic properties and districts, especially those in city centers and central business districts. The intent of the Order is to strengthen the Nation's cities by locating Federal facilities in these areas.

EO 13287 - Preserve America

Thanks for this opportunity to comment.

Larry Moore

Broken Arrow, OK