Ron, if you wish to cut to the chase, you should contact Leo Schmitz, Executive Director of the C&TS directly, so that the information you receive is not second-hand or distorted. My own perspectives on your five points are:
#1. & #2. The source of the funds (state, federal, or ticket revenues) has nothing to do with whether proposed work should be reviewed by SHPO. Currently, any work that affects"non-revenue" "contributing resources" is submitted to the SHPO's by the Executive Director in advance of that work proceeding.
As for work on "contributing resources" used in operations, buildings (e.g., Chama Depot, but not the Osier Dining Hall), and structures (e.g., Lobato trestle, but not track) are reviewed by the SHPO's. The difficult case is steam locomotives. SHPO's are not qualified to analyze running gear work, boiler work, etc., so the Commission has a special obligation to insure that locomotive work is done in a manner consistent with long-established steam locomotive practices and in conformity with FRA rules.
#3. Whether the trestles were filled using public funds or not is irrelevant. The work was done as part of trackwork upgrades (mostly paid for with appropriations from both states), but the National Register filing, done in cooperation with the SHPO's, does not define the track as a "contributing resource." However, the railroad's draft NHL submission to the NPS does define the track as a contributing resource and says that "as part of this resource are the many signs that mark the mile locations, state boundaries, speed limits, stations and sites as well as many small trestles, culverts and fills that convey water under the rails or convey the track across depressions in the landscape. Larger bridges are described individually as contributing resources."
#4.& #5. As I've already said, the filling of the trestles would have been done with state appropriations, but, being part of the trackwork, were not likely to have had specific review by the SHPO's because the track is not currently a "contributing resource."
As for the nature and extent of involvement by the SHPO's, be careful what you wish for. SHPO's know buildings, but they are not practiced at locomotive rebuilding, trackwork, and other railroading practices. Please also be aware that the SHPO's do not actually "approve" projects, instead their charge is to review the proposed work on a contributing resource and determine whether the work will have "no adverse affect" on that resource.
What needs to be stressed is that the Commission shows every intention of being dedicated to protecting and preserving the C&TS. Mistakes do happen, but any perceived shortcomings in that regard are best addressed by the Commission, and not by drawing in a state agency not well equipped to deal with railroad technologies and operating practices.
Edited 1 time(s). Last edit at 10/06/2011 03:29PM by Dick Cowles.
