In a collaborative effort to make walking and biking to school safer and more accessible, the Bath Township Safe Routes to School (SRTS) project enhanced connectivity and walkability for local students. Funded through a SRTS major grant, the project united key community partners, including Bath Community Schools, Bath Township, the Clinton County Road Commission, Michigan Department of Transportation (MDOT) Local Agency Program (LAP), and the Michigan Fitness Foundation’s SRTS team
During the planning process, Bath Township’s SRTS team identified a gap that would make it easier for students to commute to school. Filling that gap meant creating a new pathway through the James Couzens Memorial Park.
“We realized that there’s no great direct path in the middle of a five-block area. We thought the best way to bridge that gap was going through the park,” said Bath SRTS Chairperson Chris Hagerman.
The park is the historic site of the 1927 Bath School Bombing that leveled the school building. The site was later redeveloped as the James Couzens Memorial Park and dedicated to those who were victims of this act of domestic terrorism.
“If you’re just driving by, there’s nothing that would tell you what actually happened there, and what an impact it had on the community,” said MDOT LAP Historian Brian Grennell.
Because of the park’s unique historical status, it prompted review under Section 106 of the National Historic Preservation Act. The Section 106 review is for any federal or federally assisted project that has the potential to affect historic properties to ensure there are no adverse effects to the property. To work through the process, Bath partnered with the MDOT LAP Cultural Resources staff.
Grennell emphasized the importance of early coordination with MDOT LAP when historic or archaeological resources may be involved, because Section 106 is a long process. He also shared that the likelihood of a Section 106 review being required is higher, thus requiring more time, on a wholly new project than for an improvement.
The goal of the Section 106 process is to avoid, minimize, or mitigate any adverse effects caused by changes to the property.
“Archaeological site information is protected; it’s not released for public disclosure. If it was out in the public, sites could be compromised,” explained MDOT LAP Archaeologist and Tribal Liaison Patty Jo Korzeniewski. “Once we get a project scope, Brian Grennell looks at it for above ground resources and I look at it for below ground concerns, and determine if Tribal coordination is needed,” explained Korzeniewski.
“First we see if adverse effects can be avoided with alternative designs,” explained Grennell. “If there is a good case that the effects cannot be avoided, then public comment is required. MDOT LAP staff will coordinate with the State Historic Preservation Office (SHPO) on no adverse effect or adverse effect findings. We will also have to send documentation to the Federal Highway Administration, who notifies the Advisory Council in Washington, D.C. and sees if they want to participate when the project has an adverse effect.”
With the number of reviews and notifications required, the Section 106 process can take a long time, which is why Grennell and Korzeniewski both recommend coordinating with MDOT LAP Cultural Resources staff as early as possible, during the planning phase of a project.
“MDOT LAP now offers scoping. Scoping allows applicants to factor in additional time which could be necessary for survey, SHPO consultation, tribal coordination, resolution of adverse effects or 4(f) concerns that may include additional public comment,” Shared Korzeniewski. “Scoping allows the applicant the option to address identified concerns during the design phase to potentially avoid or minimize impacts. This can be especially important for projects that are large, complex, and/or involve known or reasonably anticipated concerns.”
“The big thing is early coordination. You can get ahead of the game, be aware of any potential concerns, and be able to plan for them,” Grennell said.
While there were delays to the initial timeframe to address the gaps, after the Section 106 process was completed, the route through the James Couzens Memorial Park was approved and constructed as planned.
Project Summary
The SRTS Bath project navigated the historic and archaeological review process through MDOT LAP in order to fill sidewalk gaps through a historic site in the town center.
- Total SRTS Grant Amount: $501,456
- Local Match Amount: $125,364
The project was made possible through the collaborative efforts of Bath Community Schools, Bath Township, Clinton County Road Commission, Michigan Fitness Foundation, Michigan Department of Transportation, and Federal Highway Administration.