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Projects effecting structures included in the Historic Bridge Survey (HBS) must be processed and developed in accordance with the rules contained within the Programmatic Agreement (PA) established between the Illinois Department of Transportation (IDOT), Illinois Historic Preservation Agency (IHPA) and Federal Highway Administration (FHWA). A copy of the PA is provided in Appendix “A”.

When estimating the amount of time necessary to evaluate the impact of a project on a HBS structure, it is important to remember that all bridges designated in the HBS as “primary” examples fall into at least one of the following categories:

  • Listed on the National Register of Historic Places (NRHP)

  • Determined to be eligible for listing on the NRHP

  • Located within a site or area listed on the NRHP


Documenting a projects impact and developing mitigation for a “primary” structure associated with the NRHP could require considerable time. The IDOT attempts to minimize the time required by working closely with the IHPA during project review.

The development of projects affecting a structure in the HBS typically involves a search of the Illinois bridge inventory for bridges of similar type, age and construction that could be substituted for the HBS structure. When searching for a similar structure, the search typically begins within the county developing the project, then expands into all of the counties within the IDOT District overseeing the development of the project, and lastly into all of the counties within Illinois.

Projects involving structures in the HBS typically propose one of the following three (3) alternatives:


Bypass the Existing Bridge

The option of leaving an HBS structure in place, and constructing a replacement structure in the immediate vicinity of the existing bridge, is a very effective option for minimizing or eliminating the negative impact of a project on a HBS structure. A project that bypasses a HBS structure usually involves a realignment of the approach roadway to improve highway safety.

After right-of-way issues are resolved for a project bypassing a HBS structure, the existing bridge may be located within the original owner-agency’s right-of-way or on private property. Regardless of the final jurisdictional location of the HBS structure, the original owner-agency is responsible for ensuring future maintenance and repair of the bridge. As an alternative to retaining responsibility for the HBS structure, the original owner-agency may, with the concurrence of the IDOT and the IHPA, transfer ownership and future responsibilities to another reputable agency or organization. The agency or organization with future repair and maintenance responsibility does not have to provide ready access to the HBS structure, designated parking areas for visitors, or signs to inform the public of the historical significance of the bridge. However, the responsible agency or organization must make the HBS structure available for viewing, when contacted by interested parties.

A formal 106-4(f) Report is usually not required for a project bypassing a HBS structure. In lieu of a formal report, a letter to the IDOT with maps, photos and plan information illustrating the alignment of the bypass is sufficient. The IDOT will utilize the letter and accompanying information in coordination with the IHPA, which typically occurs in an expeditious manner. Although it is not to be taken as a certainty, a final determination of “No Effect” is usually issued for a project that allows a HBS project to remain in place by utilizing a bypass.

Relocate the Existing Bridge

The option of moving an HBS structure to a new location, rather than demolishing the bridge, is an effective option for minimizing the negative impact of a project on a HBS structure. A project that relocates a HBS structure may call for the intact movement of the bridge or the disassembling and reassembling of the bridge. The new location for the HBS structure must me one that provides suitable access to the bridge, with the access being equal to or greater than that provided at the original site of the bridge.

Regardless of the final location of the HBS structure, the original owner-agency is responsible for ensuring future maintenance and repair of the bridge. As an alternative to retaining responsibility for the HBS structure, the original owner-agency may, with the concurrence of the IDOT and the IHPA, transfer ownership and future responsibilities to another reputable agency or organization. The agency or organization with future repair and maintenance responsibility does not have to provide ready access to the HBS structure, designated parking areas for visitors, or signs to inform the public of the historical significance of the bridge. However, the responsible agency or organization must make the HBS structure available for viewing, when contacted by interested parties.

A formal 106-4(f) Report is usually not required for a project that relocates a HBS structure. In lieu of a formal report, a letter to the IDOT with maps, photos and information relative to the removal and relocation plan is sufficient. The IDOT will utilize the letter and accompanying information in coordination with the IHPA, which typically occurs in a timely manner. Although it is not to be taken as a certainty, a final determination of “No Adverse Effect” is usually issued for a project that allows a HBS project to remain in place by utilizing a bypass.

Remove the Existing Bridge

Removing/demolishing an HBS structure should be the last option considered, and it should be selected only after all other options have been considered and found to be unfeasible. The owner-agency must provide public notice of its intent to remove the bridge, which should include direct contact with local historic preservation groups and a publicized notice of intent in locally distributed newspapers. Documentation of public contacts and notices must be provided with reports submitted to the IDOT for review.

A project that calls for the removal/demolition of a HBS structure must be developed in full accordance with the PA established between the IDOT, IHPA and FHWA. A formal 106-4(f) Report must be submitted to the IDOT, and coordination between the IDOT and IHPA may take several months. A final determination of “Adverse Effect” is typically issued for a project that removes a HBS structures, and a search must be conducted for structures that can be placed on the HBS as a replacement for the removed bridge.

If the IDOT and IHPA concur with the removal of the HBS structure, a Memorandum of Agreement (MOA) must be established between the owner-agency, IDOT, IHPA and FHWA. The MOA establishes the mitigations required of the owner-agency in order for the IDOT, IHPA and FHWA to concur with the implementation of the project.

Within the Bureau of Design & Environment, coordination and review of projects effecting HBS structures are accomplished within the Environment Section by the Cultural Unit.

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