MEMORANDUM OF UNDERSTANDING
ON COORDINATION OF ENVIRONMENTAL REVIEWS FOR
PIPELINE REPAIR PROJECTS
May 2004
The Council on Environmental Quality
The Department of Transportation
The Environmental Protection Agency
The Department of the Interior
The Department of Commerce
The Department of Defense
The Federal Energy Regulatory Commission
The Department of Agriculture
The Department of Energy
The Advisory Council on Historic Preservation
I. PURPOSE
The Pipeline Safety Improvement Act of 2002 (PSIA; P.L. 107-355) directed
Federal agencies and departments having jurisdiction over the permitting of work needed
for pipeline repairs to establish a coordinated and expedited pipeline repair permit review
process. The process must be designed to enable pipeline operators to commence and
complete all activities necessary to carry out pipeline repairs within the time periods to be
established and specified by the Secretary of Transportation, pursuant to the PSIA, and in
accordance with the statutory and regulatory requirements of the Participating Agencies.
Consistent with the PSIA, and in recognition of the fact that the timely repair of
both natural gas and hazardous liquid pipelines is essential to facilitate the nation’s ability
to meet the goal of sufficient availability and use of natural gas and liquid fuels, the
Participating Agencies enter into this Memorandum of Understanding (MOU).
II. BACKGROUND
Through Executive Order 13212, issued on May 18, 2001, the President declared
that it is the policy of his Administration that executive departments and agencies shall
take appropriate actions, to the extent consistent with applicable law, to expedite projects
that will increase the production, transmission, or conservation of energy. In that
Executive Order, the President directed Federal agencies to expedite their reviews of
authorizations for energy-related projects and to take other action necessary to accelerate
the completion of such projects, while maintaining safety, public health and
environmental protections.
1
The reliability and capacity of the Nation’s pipeline system are key determinants
of energy supply and price, particularly in certain regional markets. The nearly 200,000
miles of oil pipelines in the United States are the principal mode for transporting oil and
petroleum products such as gasoline, accounting for about 66 percent of all domestic
product movements. In addition, virtually all natural gas in the United States is moved
via pipeline. Insufficient domestic pipeline capacity has caused peak-load problems in
moving oil and petroleum products such as gasoline from one region of the country to
another.
The Nation’s existing pipeline infrastructure, much of which is over 50 years old,
requires regular safety and environmental reviews to ensure its reliability. Following
pipeline ruptures in Bellingham, Washington in June 1999 and Carlsbad, New Mexico in
August 2000 which caused loss of life and significant property damage, Congress enacted
the PSIA, which was signed into law by President Bush on December 17, 2002. The
PSIA established State “one-call” notification programs, expanded State oversight of
pipeline safety, improved enforcement authority of the Department of Transportation
with respect to pipeline safety, and increased enforcement penalties for violation of
pipeline safety regulations.
As directed by Section 14 of the PSIA, the U.S. Department of Transportation,
through the Research and Special Programs Administration, amended its safety
regulations and standards for the transportation of natural gas and hazardous liquids in or
affecting interstate or foreign commerce. The amended safety regulations at 49 CFR
Parts 192 and 195 require operators of certain pipelines to adopt Integrity Management
Programs (IMP). Under the IMP regulations, operators of transmission pipelines
transporting natural gas and hazardous liquids are required to assess, evaluate, repair, and
validate through comprehensive analysis the integrity of pipeline segments that, in the
event of a leak or rupture, could impact High Consequence Areas (HCA). The
regulations define HCAs to include populated areas, areas unusually sensitive to
environmental damage, and commercially navigable waterways.
The regulations also identify repair criteria or types of failures that must be
repaired within specified time limits, the length of which reflects the probability of
failure. For natural or other gas pipelines, two categories of repair characterization
(immediate, 1 year) are defined by the type, magnitude, or orientation of the anomaly, or
combination thereof. Similarly, for hazardous liquid pipelines, three categories of repair
are defined (immediate, 60 days, or 180 days). For example, for hazardous liquid
pipelines, a top dent with any indication of metal loss or cracking requires an immediate
response and action, whereas a bottom dent with any indication of metal loss or cracking
requires a response and action within 60 days. Given these criteria, pipeline operators
must characterize the type of repair required (as described in the regulations), evaluate
the risk of failure, and make the repair within defined time limits. These consensus
criteria were developed following extensive consultation with experts in other
government agencies, environmental organizations, industry, and academia, as well as
with the public, through a series of public notices, workshops, and technical meetings.
2
In addition, recognizing the need for timely repairs of pipelines to maintain
energy security, Section 16 of the PSIA directed the President to establish an Interagency
Committee to implement a coordinated environmental review and permitting process to
enable pipeline repairs within the time periods specified by the IMP regulations.
Committee activities were to include evaluation of Federal permitting requirements,
identification of best management practices (BMPs) to be used by industry, and the
development of a memorandum of understanding to provide for a coordinated and
expedited pipeline permit review process that includes the use of BMPs to enable
pipeline repairs that would result in no more than minimal adverse effects on the
environment. To implement Section 16 of the PSIA, the President issued Executive
Order 13302, adding these pipeline safety functions to the charge given the Task Force
authorized under Executive Order 13212.
The MOU enhances coordination of the processes through which agencies with
environmental and historic preservation review responsibilities under various statutes
meet those responsibilities in connection with the authorizations required to repair natural
gas and hazardous liquid pipelines that have been identified by pipeline operators as in
need of repair on a timely basis to protect life, health or physical property. The MOU
recognizes that early planning, notice, and consultation among the pipeline operator and
agencies can result in a structured process that facilitates timely decisions that can enable
critical repair actions to go forward, within the context of resource conservation.
The MOU supports the development of a comprehensive, “one-stop” information
system to allow pipeline operators and agencies alike access to the best available
information on pipeline testing and repair schedules, agency official contact information,
natural resource conservation needs, and recommendations on management practices for
testing and repair. Further, the MOU recognizes that the identification and use of BMPs
to avoid, reduce, or mitigate impacts to resources of concern can be one means of
implementing specific measures to protect affected resources and encourage increased
environmental stewardship.
III. EXISTING AUTHORITIES AND RESPONSIBILITIES
The Council on Environmental Quality (CEQ) was established within the
Executive Office of the President in 1969 by act of Congress as part of the National
Environmental Policy Act (NEPA). Its principal purpose is to formulate and recommend
national policies to promote the improvement of the quality of the environment. CEQ
has issued regulations applicable to Federal agencies implementing NEPA (40 C.F.R.
Parts 1500 through 1508).
The Department of Transportation (DOT), through its Research and Special
Programs Administration (RSPA), is responsible for establishing safety standards for the
nation’s pipeline transportation system. RSPA carries out this responsibility through its
Office of Pipeline Safety (OPS). OPS establishes and enforces minimum safety
standards for the design, construction, operation and maintenance of pipeline facilities
pursuant to 49 U.S.C. 60101 et seq.
3
The Environmental Protection Agency (EPA) is responsible for administering a
wide variety of environmental laws. The responsibilities of EPA relevant to the pipeline
permitting process include commenting on Environmental Impact Statements (EISs)
under section 309 of the Clean Air Act, participating in the Clean Water Act section 404
permit process, and issuing or reviewing authorized States’ issuance of National Pollutant
Discharge Elimination System permits for point source discharges of storm water from
construction activities that disturb areas in excess of one acre, pursuant to section 402 of
the Clean Water Act.
The Fish and Wildlife Service (FWS), within the Department of the Interior, is
responsible for assisting other Federal agencies and the public in the conservation,
protection, and enhancement of fish, wildlife, plants, and their habitats, pursuant to the
Fish and Wildlife Coordination Act (FWCA; 16 U.S.C. 661 et seq.). The FWS has
principal trust responsibility to protect and conserve migratory birds, threatened and
endangered species, certain marine mammals, and inter-jurisdictional fishes. In
particular, Section 7 of the Endangered Species Act of 1973, as amended (ESA, 16
U.S.C. 1531 et seq.), requires that Federal agencies insure that the actions they authorize,
fund, or carry out are not likely to jeopardize the continued existence of listed species or
destroy or adversely modify their designated critical habitat. Further, the Migratory Bird
Treaty Act (MBTA; 16 U.S.C. 703-712), prohibits the taking, killing, possession, and
transportation of migratory birds, their eggs, parts and nests, except when specifically
authorized by the Secretary of the Interior. Federal regulatory agencies and their
applicants for pipeline repair projects are required to consult with the FWS on projects
potentially affecting any of these resources. The FWS also consults on projects
potentially affecting fresh water or marine resources and water quality. In addition, the
FWS manages the National Wildlife Refuge System (NWRS), and may authorize use by
permit for areas within the NWRS.
The Bureau of Land Management (BLM), within the Department of the Interior,
is responsible for the management of Federal lands. The BLM is responsible for issuing
right-of-way grants and permits authorizing the transportation of oil, natural gas,
synthetic liquid or gaseous fuels, or any refined products produced therefrom, by
pipelines using Federal lands. Section 28 of the Mineral Leasing Act of 1920, as
amended, gives BLM the authority to issue right-of-way grants and permits for oil and
gas pipelines through all lands owned by the United States, except lands in the National
Park System, lands held in trust for an Indian or Indian tribe, and lands on the Outer
Continental Shelf.
The National Park Service (NPS), within the Department of the Interior, may
issue right-of-way permits only for those uses or activities specifically authorized by
Congress and only if there is no practicable alternative to such use of NPS lands. There
are no general authorities for issuance of right-of-way permits for gas or other petroleum
product pipelines across units of the National Park System. However, in individual
instances, park-specific legislation provides for such authorization, and some NPS lands
have been acquired subject to gas or other petroleum product pipelines easements. The
4
Organic Act (16 U.S.C. 1) and subsequent amendments (16 U.S.C. 1a) direct the NPS to
manage all park lands to protect and preserve natural and cultural resources.
The Minerals Management Service (MMS), within the Department of the
Interior, is responsible for issuing and enforcing regulations to promote safe operations,
environmental protection, and resource conservation on the Outer Continental Shelf
(OCS). The MMS is responsible for granting rights-of-way through submerged lands of
the OCS. In addition, the MMS regulates pipelines under the jurisdiction of the
Department of the Interior in accordance with MMS policies, practices, and requirements
issued under 30 CFR Part 250, Subpart J. MMS and DOT coordinate OCS pipeline
inspection and repair activities in accordance with the 1996 MMS/DOT national
Memorandum of Understanding and/or other regional agreements (e.g.. the “Offshore
California Pipeline Inspection Survey Plan” and its implementing Memorandum of
Agreement) as applicable.
The Bureau of Indian Affairs (BIA), within the Department of the Interior, is
charged with the administration of Federal Indian policy and the discharge of the Federal
trust for American Indian Tribes, Alaska Native villages and tribal organizations. BIA is
responsible for approving rights-of-way across lands held in trust for an Indian or Indian
Tribe. In addition, regarding natural gas and all rights-of- way for energy resource
transport, BIA must consult and coordinate through government-to-government relations
with any affected Tribe.
The National Marine Fisheries Service (NMFS), an office of the National Oceanic
and Atmospheric Administration (NOAA) within the Department of Commerce, is
responsible for a variety of activities in marine and coastal ecosystems as mandated by
several statutes and authorities. These activities include conserving threatened and
endangered species, protecting marine mammals, managing commercial and recreational
fisheries, and protecting marine and coastal habitats. These activities are conducted
pursuant to the ESA, the Marine Mammal Protection Act (MMPA), the MagnusonStevens Fishery Conservation and Management Act (MSA), and the FWCA. Federal
agencies involved in pipeline repairs that have potential effects on threatened and
endangered species or essential fish habitat must consult with NMFS pursuant to the ESA
and the MSA. For any pipeline repair that would incidentally take a marine mammal, an
authorization pursuant to the MMPA must be obtained.
The National Ocean Service (NOS), an office of the National Oceanic and
Atmospheric Administration (NOAA) within the Department of Commerce, administers
the Coastal Zone Management Act (CZMA) and approves and works with states to
implement comprehensive Coastal Management Programs and National Estuarine
Research Reserves and mediates disputes regarding CZMA issues. Under CZMA section
307(c)(3)(A), applicable states must concur with consistency certifications submitted
with permit applications for activities affecting any land or water use or natural resource
of the coastal zone before Federal agencies can issue their approvals. NOS also manages
designated National Marine Sanctuaries (NMS) and coastal protection and restoration
activities. Pipeline repairs within a designated NMS will likely require a permit
5
(pursuant to NMS regulations at 15 CFR Part 922), and pursuant to Section 304(d) of the
National Marine Sanctuaries Act, Federal actions near NMS may require consultation
with the Secretary of Commerce.
The Army Corps of Engineers (COE), within the Department of Defense (DOD),
is responsible for the administration of laws for the protection of waters of the United
States, pursuant to section 10 of the Rivers and Harbors Act of 1899 (RHA; 33 U.S.C.
403), section 404 of the Clean Water Act of 1972, as amended (CWA; 33 U.S.C. 1344),
and section 103 of the Marine Protection, Research, and Sanctuaries Act of 1972
(MPRSA; 33 U.S.C. 1413). The RHA authorizes all work and or structures in or
affecting the course, condition, location, or capacity of navigable waters of the United
States and artificial islands, installations, or other devices on the Outer Continental Shelf.
The CWA authorizes the discharge of dredged or fill material into the waters of the
United States, including wetlands. The MPRSA authorizes the transportation of dredged
material excavated from navigable waters of the United States for the purpose of
dumping it in ocean waters. It is expected that the COE may authorize most pipeline
repair activities under these Acts through the use of existing nationwide permits. Where
the impacts on the aquatic resources may be more than minimal either individually or
cumulatively, individual permits may be warranted, and in emergency situations, as
defined by the COE, emergency permits may be used as necessary. Letters of permission
and/or regional general permits may be established at the local and regional level to
further abbreviate the permitting process. The different permitting program requirements
and conditions are set forth in 33 CFR Parts 320-330.
The Federal Energy Regulatory Commission (FERC) is responsible for
authorizing the construction and operation of interstate natural gas pipelines. It issues
certificates of public convenience and necessity for such pipelines under section 7 of the
Natural Gas Act of 1938, as amended (NGA), and authorizes the construction and siting
of facilities for the import or export of natural gas under section 3 of the NGA. It also
authorizes the construction and operation of natural gas pipelines pursuant to the Natural
Gas Policy Act. The FERC's authorization requires that interstate pipelines maintain
service at certificated levels. Pipeline repair projects can often be accomplished within
existing authorizations and exemptions.
The Forest Service (FS), within the Department of Agriculture, is responsible for
the management of 192 million acres of National Forest System (NFS) lands. Many
hundreds of miles of natural gas and hazardous liquid pipelines cross NFS lands. Most of
these pipelines are permitted by BLM-issued rights-of-way grants, pursuant the authority
granted to the Secretary of the Interior in section 28 of the Mineral Leasing Act of 1920,
as amended. Those that are not are instead permitted by FS-issued special use
authorizations.
The Department of Energy (DOE) is charged with developing and coordinating
national energy policy. DOE protects U.S. national and economic security by promoting
a diverse supply and delivery of reliable, affordable, and environmentally sound energy.
DOE’s Office of Energy Assurance (EA) works in close collaboration with other Federal
agencies, State and local governments, and the private sector to protect the Nation against
6
severe energy supply disruptions such as those that can result from safety related
reductions in pipeline operating pressures1.
The Advisory Council on Historic Preservation (ACHP) reviews and provides
comments with regard to actions by Federal agencies that may affect properties listed or
eligible to be listed on the National Register of Historic Places pursuant to the National
Historic Preservation Act.
IV. PARTICIPATING AGENCY AGREEMENT
The Participating Agencies hereby agree to work with each other, and with other
entities as appropriate (e.g., State agencies), to ensure that timely decisions are made to
enable pipeline repairs to occur within the time periods specified by rule by the DOT,
while ensuring that the environmental review and permitting responsibilities of each
agency are met.
Specifically, each Participating Agency agrees to:
A. recognize that the DOT classifications of pipeline repairs mandate certain pipeline
repairs within specific time frames;
B. provide information to facilitate information exchange through the National
Pipeline Mapping System (NPMS) between pipeline operators and agencies with
safety, environmental review, or energy supply assessment responsibilities,
including:
1. information from pipeline operators on the schedule for testing of their
natural gas and hazardous liquid pipelines pursuant to DOT’s Integrity
Management Program (IMP) regulations;
2. relevant contact information for agency officials with direct authority over
permitting activities for each specific pipeline segment in the NPMS;
3. regional and field level information, where practicable, on resources of
concern, including, but not limited to, species and habitats protected under
the ESA;
4. information on permits or authorizations that may be required to conduct
repairs in areas in and around specific pipelines in the NPMS;2 and
1
DOT’s IMP regulations for pipelines specify timeframes within which certain types of repairs must be
completed. When a pipeline operator cannot complete a repair within the required timeframe, those
regulations require the operator to reduce the pipeline’s operating pressure by 20% or more to ensure its
continued safe operation; this reduction in product flow can have significant adverse impacts not only on
the supply of fuel regionally, but also on the price of fuel nationally.
7
5. information on specific pipeline segments in the NPMS where disruption
of the energy supply due to shut-down or operating pressure reductions
could create critical risks to public health and safety3;
C. participate in appropriate pre-inspection planning and coordination to determine,
as much as possible, what actions would need to be undertaken should a repair be
necessary.
D. give priority to processing of permits for those repairs classified as “immediate”
or “time-sensitive” pursuant to DOT’s repair characterizations over other less
urgent permit application reviews;
E. work together at all appropriate administrative levels to define, regularly review,
and where necessary, refine a set of Best Management Practices (BMPs) that,
when used in making pipeline repairs, will aid the expedited consideration of
permitting requests, minimize adverse impacts on the environment and reduce the
need for post-repair remediation;
F. establish a Working Group to develop guidance documents with procedures that
can be used to coordinate and expedite repair permitting processes for those
repairs classified as “immediate” or “time-sensitive” pursuant to DOT’s repair
characterizations; and
G. where disagreements arise among the Participating Agencies or between one or
more Participating Agencies and State and local agencies and the pipeline
operator, participate in any process established by the Ombudsman designated
pursuant to 49 U.S.C. 60133(e) to assist in resolving those disagreements,
consistent with the protection of human health, public safety, and the
environment.
V. IT IS MUTUALLY AGREED AND UNDERSTOOD THAT:
A. Nothing in this MOU will be construed by the Participating Agencies to require
the obligation, appropriation, or expenditure of any money from the U.S.
Treasury.
2
The exchange of information in this format does not replace a formal consultation or fulfill any
consultation requirements under the ESA or fulfill the need to obtain appropriate permit authorizations
under the CWA or RHA.
3
When a repair cannot be performed within the required timeframe, DOT regulations require the operator
to reduce the pipeline’s operating pressure by 20% or as much more as is necessary to ensure its continued
safe operation; this reduction in product flow can have significant adverse impacts not only on fuel prices
(as when regional shortages cause national price spikes), but also on public health and safety (as when fuel
shortages during peak usage times threaten the availability of heat, lights, and clean water).
8
B. This MOU may be modified or amended upon written request of any party hereto
and the subsequent written concurrence of all of the Participating Agencies.
Participation in this MOU may be terminated sixty (60) days after providing
written notice of such termination to the other Participating Agencies.
C. This MOU is intended only to improve the working relationships of the
Participating Agencies in connection with expeditious decisions with regard to
coordination of environmental reviews for pipeline repair projects and does not
create any right, benefit, or trust responsibility, substantive or procedural,
enforceable at law or equity by any person or party against the United States, its
agencies, its officers, or any other person.
D. This MOU is to be construed in a manner consistent with all existing laws and
regulations.
E. This MOU neither expands nor is in derogation of those powers and authorities
(including existing authorities described in Part III of this Memorandum) vested
in the Participating Agencies by applicable law, statutes, regulations, or Executive
Orders, nor is it intended to modify or supersede any other applicable interagency
agreements existing as of the date of this MOU.
F. The Participating Agencies intend to fully carry out the terms of this MOU. All
provisions in this MOU, however, are subject to available resources.
G. This MOU does not affect any guidelines related to information quality issued by
the Participating Agencies in connection with section 515 of the Treasury and
General Government Appropriations Act for FY 2001 (P.L. 106-554).
Information disseminated pursuant to this MOU will be subject to the information
quality guidelines of the Participating Agency that disseminates such information,
and requests for correction of such information will be addressed by such
Participating Agency according to that Agency’s established guidelines.
VI. PRINCIPAL CONTACTS
Each Participating Agency hereby designates, as shown in Appendix A, a
principal point of contact for that agency. These contacts may be changed at the
Participating Agency’s discretion upon notice to the other Participating Agencies.
9
VII. SIGNATORIES
10
11
12
APPENDIX A
PRINCIPAL CONTACTS
The following are the principal initial contacts for each agency:
Council on Environmental Quality
Bryan Hannegan
Associate Director for Energy and Transportation
Council on Environmental Quality
722 Jackson Place, NW
Washington, DC 20503
bryan_hannegan@ceq.eop.gov
202-395-0801 (voice)
202-395-3744 (fax)
Dinah Bear
General Counsel
Council on Environmental Quality
722 Jackson Place, NW
Washington, DC 20503
dinah_bear@ceq.eop.gov
202-395-7421 (voice)
202-456-0753 (fax)
Department of Transportation
Stacey Gerard
Associate Administrator for Pipeline Safety
Office of Pipeline Safety
Research and Special Programs Administration
U.S. Department of Transportation
400 Seventh Street SW
Washington, D.C. 20590
stacey.gerard@rspa.dot.gov
202-366-4595 (voice)
202-366-4566 (fax)
Roger Little
Director, Information Systems and Analysis
Office of Pipeline Safety
Research and Special Programs Administration
U.S. Department of Transportation
400 Seventh Street SW
Washington, D.C. 20590
roger.little@rspa.dot.gov
202-366-4569 (voice)
202-366-4566 (fax)
13
Environmental Protection Agency
Cliff Rader
Office of Federal Activities (2252-A)
U.S. Environmental Protection Agency
1200 Pennsylvania Ave, NW
Washington, DC 20460
rader.cliff@epa.gov
202-564-7159 (voice)
202-564-0070 (fax)
Department of the Interior
Lee Dickinson
Special Park Uses Program Manager
National Park Service
1849 C Street, NW (code 2460)
Washington, DC 20240
lee_dickinson@nps.gov
202-513-7092 (voice)
202-371-2401 (fax)
Robin Nims Elliott
Chief, Branch of Federal Activities
Division of Federal Program Activities
U.S. Fish and Wildlife Service
4401 North Fairfax Drive
Arlington, VA 22203
Robin_Nimselliott@fws.gov
(703) 358-2183 (voice)
(703) 358-1869 (fax)
Patrick Leonard
Chief, Division of Consultation, Habitat Conservation Planning,
Recovery, and State Grants
U.S. Fish and Wildlife Service
4401 North Fairfax Drive
Arlington, VA 22203
Patrick_Leonard@fws.gov
(703) 358-2171 (voice)
(703) 358-1735 (fax)
14
Richard Clingan
Physical Scientist
Minerals Management Service
381 Elden Street
Herndon, VA 20170-4817
Richard.Clingan@mms.gov
703-787-1027 (voice)
703-787-1555 (fax)
Ron Montagna
Senior Realty Specialist, Rights-of-Way Management
Bureau Of Land Management
1849 C Street NW (MS 100 LS)
Washington, DC, 20240-9998
ron_montagna@blm.gov
202-452-7782 (voice)
202-452-7708 (fax)
Bureau of Reclamation
TBD
Bureau of Indian Affairs
TBD
Department of Commerce
Mi Ae Kim
Biologist, Office of Protected Resources (F/PR3)
National Marine Fisheries Service
1315 East-West Hwy
Silver Spring, MD 20910
mi.ae.kim@noaa.gov
301-713-1401, x159 (voice)
301-713-0376 (fax)
Department of Defense
Russell L. Kaiser
Senior Regulatory Program Manager
U.S. Army Corps of Engineers
441 G Street, NW
Washington, DC 20314
russell.l.kaiser@hq02.usace.army.mil
(202) 761-4614 (voice)
(202) 761-4150 (fax)
15
Federal Energy Regulatory Commission
Richard R. Hoffmann
Director, Division of Gas - Environment and Engineering
Federal Energy Regulatory Commission
888 1st Street, NE
Washington, DC 20426
richard.hoffmann@ferc.gov
(202) 502-8066 (voice)
(202) 208-2353 (fax)
Department of Agriculture
TBD
Department of Energy
Christopher J. Freitas
Program Manager, Natural Gas Storage and Pipeline Reliability
FE-32/Forrestal Building
1000 Independence Ave., SW
Washington, DC 20585
christopher.freitas@hq.doe.gov
(202) 586-1657 (voice)
(202) 586-6221 (fax)
Advisory Council on Historic Preservation
Don L. Kilma
Office of Federal Programs
Advisory Council on Historic Preservation
Old Post Office Building
1100 Pennsylvania Ave., NW, Suite 809
Washington, DC 20004
dklima@achp.gov
(202) 606-8504 (voice)
(202) 606-8672 (fax)
16
