Jeff, as you may know in the past year the Commission has codified most of its policies in a "Policies and Practices Manual", updated 7/21/12, which can be found in the Commission's portion of the C&TSRR web site: [
www.cumbrestoltec.com].
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Historical Preservation and SHPO Oversight
"The Commission’s preservation policies are grounded in a fundamental purpose of the Compact which is “to promote the public welfare … by preserving, as a living museum for future generations, a mode of transportation that helped in the development and promotion of the territories and states, …”. In pursuing this purpose the Commission has adopted policies, in cooperation with the Friends, that have resulted in the C&TSRR being recognized and listed in the National Register of Historic Places as a site of National Significance.
"With that designation come certain responsibilities which include implementing practices that satisfy the preservation and rehabilitation standards and guidelines specified in the Secretary of the Interior’s Standards for the Treatment of Historic Properties (i.e., “SIS”) at www.nps.gov/history/hps/tps/standguide. Two basic mechanisms ensure compliance:
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Review by the States’ Historical Preservation Offices. The Commission fully supports cooperation with the SHPO’s of the two states which have jurisdiction over such matters. Proposed projects that are subject to SHPO review, whether originated by the Friends, Commission staff, or contractors, are submitted in written form to the Commission in advance and thence are forwarded to the appropriate SHPO for review, modification if necessary, and concurrence before any work commences. As a courtesy, both SHPO’s are usually notified whenever historic assets are, or may be, involved in a project, however the SHPO for the state in which the project is located has the jurisdiction.
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Compliance with SIS Guidelines. Historic preservation and rehabilitation projects are conducted in accordance with the SIS guidelines. The Commission requires compliance by contractors, such as the Friends and the railroad’s operator, with pertinent SIS guidelines when working on historic properties.
"The Commission intends to further promote recognition of the C&TSRR as a historical property of national significance, including support for efforts to designate the railroad as a National Historic Landmark.
"The Commission maintains a record of decisions taken regarding its preservation policies and practices, including by way of example its 1995 decision regarding visual preservation of the Chama Yard in which the NM SHPO concurred."
To the best of my knowledge the Friends in its projects adhere faithfully to these policies which are enforced by the Commission. This is not to say that there have never been changes to the "historic fabric" of the railroad, but these have usually been due to FRA regulations which any operating railroad has to satisfy (e.g., new bridge and trestle reg's), or occasional mistakes (e.g., the Chama ash pit replacement) when established review practices were not observed by operators or Commission staff.
