NORTHEAST FACILITIES SERVICE OFFICE
UNITED STATES POSTAL SERVICE

September 13, 2005
Honorable Tom Gunderson, Mayor
Village of Aurora
456 Main Street
Aurora-on-Cayuga, NY 13026

Re: Aurora NY 13026 Main Office

Dear Mayor Gunderson: This is a follow up to the meeting I had with you and a number of Village officials regarding the Aurora post office facility. Postal regulations require that we keep your office and the local community advised as we consider expansion or relocation of the present office.

The most significant operational concern with the present facility is the limited parking and lack of maneuvering area which combine to preclude installation of a loading dock or scissors lift. Present conditions necessitate that the mail dispatch truck back in from Main Street (NYS Route 90) across the pedestrian sidewalk to load and unload at the front of the building. This activity not only created a heightened potential for pedestrian injury by backing on a public street, but also blocks the sidewalk while the truck is present, forcing pedestrians into the street. Due to a lack of available site adjacent to the existing facility, this situation cannot be corrected, and operational requirements cannot be met. Therefore, expansion of the present facility must be eliminated from future consideration.

In the near future, the Postal Service will advertise for both an existing building to house the post office, or a site on which to construct a new post office. In accordance with Postal Service policy, preference will be given to the utilization of an existing building. If a suitable existing building cannot be located, then a new facility will be constructed.

In compliance with Postal Service regulations, your office or any member of the co nmunity may object to this decision to relocate the post office within the next 30 days. Correspondence should be directed to the Vice President, Facilities, and sent to my attention at the address below. A response will be provided within 15 days of the receipt of the correspondence.

Our analysis of the requirements for this facility indicates that approximately 1,600 square feet of net interior space is needed. Additionally, approximately 275 square feet of loading platform space is needed, and a site size of approximately 26,000 square feet. The actual areas of a selected location may vary significantly from these idealized requirements, due to property configuration, availability of joint use areas, etc. I would suggest an area of consideration bounded by Sherwood Road to the north, Dublin Hill road to the south, Court Street to the east, and Cayuga Lake to the west.

Given the previous public meeting concerning the post office relocation, and the apparent wjdespread public knowledge of the issues involved, I do not believe that another public meeting is necessary to meet the requirements of the Postal Service Community Relations regulations. However, please advise if you believe another public meeting would be beneficial.

With regards to Section 106 of the National Historic Preservation Act of 1966, as amended, concept approval for this project was provided by Postal Service Facilities Headquarters on March 10' 2005. That is the date on which the Postal Service determined this project to have become an undertaking for the purposes of the Section 106 review requirements. The Village and any potential respondents to the forthcoming solicitation are cautioned not to take any action which might foreclose the State Historic Preservation Officer's (SHPO) opportunity to review applicable activities.

Sincerely, Paul J. Senk Manager, Real Estate
6 Griffin Road North
Windsor CT 06006-0300
FAX: 860/285-1287

Cc:
David Kulakowski, Postmaster, Aurora NY 13026
Anne Marafino, Post Office Operations Manager

-------- Original Message --------
Date: Mon, 19 Sep 2005 13:29:41 -0400
From: Rick Lord. NYS Office of Parks, Recreation & Historic Preservation
To: <dallan.c.wordekemper@email.usps.gov>,<psenk@email.usps.gov>

Mr. Wordekemper and Paul [Senk]:

...the decision to relocate the post office is itself an undertaking and by committing to do so without exploring the rehabilitation of the existing facility, the USPS has foreclosed our ability to comment.

Also, several parties---the National Trust for Historic Preservation, the Preservation League of New York State, and the Aurora Coalition---have all requested the opportunity to be "consulting parties" under 106. Leaving them, and the SHPO, out of the loop does not fulfill the agency's responsibilities under Section 106. Taking into account the level of controversy and soliciting public comment is a requirement of 36 CFR 800.2 (d):

(1) Nature of involvement. The views of the public are essential to informed Federal decisionmaking in the section 106 process. The agency official shall seek and consider the views of the public in a manner that reflects the nature and complexity of the undertaking and its effects on historic properties, the likely interest of the public in the effects on historic properties, confidentiality concerns of private individuals and businesses, and the relationship of the Federal involvement to the undertaking.

(2) Providing notice and information. The agency official must, except where appropriate to protect confidentiality concerns of affected parties, provide the public with information about an undertaking and its effects on historic properties and seek public comment and input. Members of the public may also provide views on their own initiative for the agency official to consider in decisionmaking.

We've still had no response to several e-mails to you as FPO requesting clarification of the 106 review and its status: Mr. Moncrief's letter advised comments were being sought under 106, Paul's letter to the Trust stated no 106 action had yet occurred.

The SHPO asks that the USPS refrain from taking any action---including deciding whether to move before its current lease has expired---until the proper 106 consultation has been initiated and the public has had an opportunity to comment. Thank you.

Rick Lord
NYS Office of Parks, Recreation & Historic Preservation
Peebles Island State Park, P.O. Box 189
Waterford, New York 12188-0189

-------- Original Message --------
Subject: Aurora, NY - your letter
Date: Mon, 19 Sep 2005 14:04:07 -0400
From: K.A.Hindenlang
To: Senk, Paul J - Windsor, CT <paul.j.senk@usps.gov>
CC: Wordekemper, Dallan C - Arlington, VA

Subject: RE: Aurora
Date: Mon, 15 Aug 2005 14:25:54-0700
Senk, Paul J - Windsor, CT wrote:

Dear Ms. Hindenlang:

I have been working towards a formal statement to the Village since my meeting with a number of village officials last month. I plan have it out this week. As a part of that effort, I am attempting to create a contact list of organizations and individuals who have expressed interest in this matter. I hope that will improve the flow of information to the Aurora community regarding this important issue.


Dear Mr. Senk,

This past weekend, there were rumors in my village that you had sent a letter to our mayor stating that the USPS will move its facility in Aurora.

As interested individuals and organizations had not been contacted with this new information, as you promised above, I thought the rumor unfounded. Nevertheless, I stopped by the Village Clerk's Office this morning to ask to view any recent USPS correspondence and was told that none had been received.

This afternoon, I have found that supporters of Pleasant Rowland's LLC do, in fact, have copies of a 9/13 letter from you, and are circulating them with a petition to support relocation of our postal facility.

Could you please answer the following questions?

* How is it that Rowland's Aurora Foundation LLC has obtained your letter before it has been received by our Village Government?

* When, in accordance with 39 C.F.R. § 241.4, will you issue your "initial news release" so that the public might be informed of your decision?

* How could you make your decision to relocate prior to the required Section 106 Review?

* Will you please fulfill the USPS obligation to hold a public hearing on this issue under C.F.R. § 241.2(c)(3) and (4)(i)?

Thank you very much for your attention to this matter,

Karen A. Hindenlang


-----Original Message-----
From: Senk, Paul J - Windsor, CT
Sent: Tuesday, September 20, 2005 1:47 PM
To: Lord, Richard (PEB)
Cc: Wordekemper, Dallan C - Arlington, VA; Kulakowski, David R - Aurora, NY
Subject: RE: Aurora

Rick:

...Our Postal service Community Relations regulations do not always fit very well with the 106 review process, but I will do what I can to ensure that the intent of both are met, as well as the requirements of our acquisition policies.

As I understand it, in this case your position is that we have foreclosed the 106 process by deciding that we need to relocate the post office in Aurora. The Postal Service has reviewed the site, and determined that the inadequacies of the facility cannot be rectified within the constraints of the current property. It is physically not possible. Therefore, a relocation is indicated. That should be considered a working hypothesis at this time. If in response to a public solicitation an offer is made to expand the present post office site and provide the means to correct the deficiencies without relocating the post office to another parcel, that will be considered. Of course, the SHPO will be consulted in that consideration. But I can't support a review of an alternative that is just not feasible. However, if the SHPO would like to comment on the Postal Service's decision to seek alternate quarters, please do. I would be happy to review any suggestions the SHPO may have. Expansion is still our first preference. However, I must keep in mind that the present lease expires in 2009, and if the Village decides not to extend the lease, expansion will no longer be an alternative at all.

...I have not left anyone "out of the loop." I will ensure that everyone who wants to comment on this matter will have ample opportunity to do so, especially those who have contacted the Postal Service directly. I will do everything I can to make sure that the requirements you cited are met before any irrevocable action is taken....

Paul

~~~~~

NYS Office of Parks, recreation and Historic Preservation

September 27, 2005

Mr. Don Klima, Executive Director
Advisory Council on Historic Preservation
Old Post Office Building, Suite 809
1100 Pennsylvania Avenue, NW
Washington, DC 20004


Dear Mr. Klima:

The New York State Historic Preservation Office (SHPO) is writing to update the Advisory Council about this United States Postal Service (USPS) undertaking pursuant to 36 CFR 800, Appendix A, Section (c)(2) and (3) because:

1.) Mr. Dallan Wordekemper, the USPS Federal Preservation Officer, has not responded to repeated SHPO calls or to our e-mails of 2/24/05, 3/21/05, 4/22/05 or 8/15/05;

2.) The USPS work is part of a larger undertaking executed by the same sponsor, the Aurora Foundation, which is a partnership involving Wells College and the Rowland Foundation;

3.) That undertaking has already had an Adverse Effect on the Aurora Village-Wells College Historic District, listed in the National Register of Historic Places on 11/19/80;

4.) Parking resulting from this undertaking would “complete” the larger project, a fact acknowledged in the Village’s official State Environmental Quality Review Act (SEQRA, or state-level NEPA) documents which intentionally segmented the required parking from the reviews conducted in 2001 and 2002;

5.) The Aurora Foundation is aware of the required Section 106 review because it was copied on numerous SHPO letters issued since 2001 but nonetheless continued to gut the historic Heary Building, which is the subject of the USPS undertaking;

6.) That action constitutes the intentional foreclosure discussed in Section 110(K) of the National Historic Preservation Act and the Council’s regulations 36 CFR Part 800.9(c)(1) implementing it;

7.) The USPS will not provide a consistent answer about the status of the Section 106 review, or even if one has been initiated:

a) Regional Historic Preservation Officer William Moncrief wrote the SHPO on 10/19/04 to request SHPO comments “in consonance with the provisions of the Intergovernmental Cooperation Act and the Historic Preservation Act;”

b) On 12/17/04 his supervisor, Paul Senk, responded to the National Trust for Historic Preservation’s request for consulting party status by stating that the USPS had not yet initiated a 106 process;

c) On 9/13/05 Mr. Senk wrote Village Mayor Thomas Gunderson to advise that the Post Office must relocate, cautioned that the sponsor and Village should not take any action that would foreclose our ability to explore alternatives (see 3 and 4 above), that no public hearing is necessary (see 8 and 9 below) to meet the requirements of the Postal Service Community Relations regulations, that public comments should be provided by 10/11/05, and that the USPS had determined on 3/10/05 that it had a Section 106 undertaking;

d) The letter was written to the Mayor and, per Mr. Senk, was copied only to the Aurora Postmaster and select staff in the USPS Windsor, CT Regional Office;

e) Because the 9/13/05 letter was not copied to any of the Aurora residents who’ve written the USPS in the past, to the SHPO, or to any of the parties who’ve requested consulting party status---the National Trust, the Preservation League of New York State, and the Aurora Coalition---it is difficult to understand how the USPS would expect to receive any public comment by October 11.