This is a post about the boring but necessary topic of CEQA mitigation. I thought I would compile some of the mitigation language I see into a "BEST PRACTICES" example. The example below is a CEQA compliant Level 2 HABS mitigation for a significant historic district, campus, farmstead or any multi-unit grouping of resources. This example follows the Secretary of the Interior's Standards for Architectural, Engineering and Landscape Documentation. If you are in need of a mitigation for an EIR or MND, follow this format (with adjustment of the number of views and local libraries as appropriate).
HALS photograph of Grandma Prisbrey's Bottle Village, Simi Valley, California. HALS-CA-42-16
Mitigation Measure MM-CUL-__:
The existing buildings, district and the existing condition shall be documented for the historic record. Prior to project commencement, demolition, alteration, grading, or changes to surrounding context, applicant will arrange for the preparation of historical resource documentation of the district to Historic American Buildings Survey (HABS) Level 2 standards according to the Secretary of the Interior’s Standards and Guidelines for Architectural and Engineering Documentation. This HABS documentation will include large-format black-and-white photographs, descriptive and historical narrative (plus relevant contexts), and limited measured drawings.
The HABS report shall:
1. Be prepared by historic preservation professionals meeting the Secretary of the Interior’s Professional Qualifications Standards following the HABS “Guidelines for Historical Reports"
https://www.nps.gov/hdp/standards/HABS/HABSHistoryGuidelines.pdf2. Include photographs taken with large format (4 X 5" or 5 x 7") film by a photographer with demonstrated experience in creating HABS documentation following the “HABS/HAER/HALS Photography Guidelines”
https://www.nps.gov/hdp/standards/PhotoGuidelines.pdf. The photographs shall include a minimum of 36-40 or 50-60
(INSERT APPROPRIATE NUMBER) views including exterior views of the district, limited exterior elevations for each building, key interior features, key spatial relationships among buildings, character defining features of the district and circulation within the district, exterior hardscape features and views of the context that will be altered by the project.
3. Include drawings: an overall plan of the district with all historic elements labeled will be drawn from a measured survey of the district, and 3-5 limited drawings of the most significant structures shall be documented with measured drawings to HABS drawing standards and plotted on vellum to HABS archival standards following the “Recording Historic Structures and Sites with HABS Measured Drawings”
https://www.nps.gov/hdp/standards/HABS/HABSDrawings.pdf4. Include written historical descriptive data, index to photographs, and photo keymap and include copies of historic photographs, if available.
5. Be put into the public domain and distributed to the following repositories for use by the public, future researchers and educators.
a. Donation to the National Park Service HABS Collection at the Library of Congress - One copy of report, drawings, contact prints and one set of negatives following "Preparing HABS/HAER/HALS Documentation For Transmittal”
https://www.nps.gov/hdp/standards/Transmittal.pdf.b. Donation to Museum of Local County - One bound archival copy including all of the report and 8x10 archival photographic prints and 11x17 plans and a DVD of the digital files.
c. Donation to Local Main Library - One bound archival copy including all of the report and 8x10 archival photographic prints and 11x17 plans and a DVD of the digital files.
For a single resource insert this number 2 and 3 text:
2... The photographs shall include a minimum of 10-12 or 22-25 (INSERT APPROPRIATE NUMBER) views including context views of the property, exterior views of the building, facade views, character defining features and details, and interior features and volumes.
3. ... an overall floorplan of the building with will be drawn from a measurements by a qualified architect or documentation team. Drawings of the most significant features/facades shall be documented with measured drawings to HABS drawing standards and plotted on vellum to HABS archival standards following the “Recording Historic Structures and Sites with HABS Measured Drawings”
https://www.nps.gov/hdp/standards/HABS/HABSDrawings.pdf
For a landscapes or engineering resources:
For resources like bridges or foundries that are significant for engineering and technology, replace the HABS text with references to the Historic American Engineering Record (HAER) and for resources like parks, cemeteries or cultural landscapes replace the HABS references and include links to the Historic American Landscapes Survey (HALS).
NOTE 1: For Federal Undertaking mitigations (any project with more than $1 in federal funding or needing a federal permit that has a adverse impact on a historic resource) Section 106/NEPA compliant mitigations require a second archival copy for the State Office of Historic Preservation to be added to the above transmittals. Review of the documentation by the Western Regions Office of the National Park Service is also required for Federal undertakings so the documentation is not a donation but required by an MOA, PA, etc., and must follow those additional stipulations.
Note 2: If there is an additional interpretation mitigation: Data and photos from the HABS documentation shall be incorporated into the interpretive/commemorative strategies for the site under a separate mitigation measure, as appropriate.
For more Answers take a look at the
Frequently Asked Questions section of our website if you’d like more information about HABS/HAER/HALS
Stephen Schafer, Photographer
Ventura, California
805-652-1000
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