2025 3 18 Packet 2

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March 4th, 2025, Page 9 
kimley-horn.com 10 Lea Ave, Suite 400, Nashville, TN 37210 615 564 2701 
 
not as part of a larger district. If TDOT and/or TN-SHPO require survey and evaluation of the entire campus, 
this will be considered Additional Services beyond this scope of services.  
Once RGA completes the Section 106 Historic Architecture Resources Survey, the Consultant will 
incorporate the draft report into TDOT’s Section 106 Assessment form template and submit the Section 
106 Assessment to TDOT for review and comment. TDOT will submit the report to the TN-SHPO for review. 
Assumptions: 
▪ If additional coordination with TDOT and/or the Tennessee State Historic Preservation Office (TN-
SHPO) is required or if additional historic architecture documentation is needed past the 
preparation of the Section 106 Historic Architecture Resources Survey previously mentioned, this 
work can be completed by the Consultant’s subconsultant  but will be considered Additional 
Services beyond this scope of services.  
 
Section 106 – Archaeology 
Given the proposed project may warrant the acquisition of right-of-way and/or easements and may warrant 
ground disturbance of previously undisturbed areas, the Consultant’s subconsultant, Richard Grubb & 
Associates (RGA), will be responsible for preparing a Phase I Archaeological Survey to identify historic and 
prehistoric archaeological sites within the project’s anticipated APE. RGA will present the results of the 
Phase I Archaeological Survey in a report that meets the Secretary of the Interior’s Standards and 
Guidelines for Archaeology and Historic Preservation  (1983) and complies with the Tennessee SHPO 
Standards and Guidelines for Archaeological Resource Management Studies  (October 2018) and the 
TDOT Phase I Archaeological Survey Scope of Work  (2021), if applicable. RGA will perform this work 
pursuant to Section 106 of the National Historic Preservation Act (NHPA), as amended.  
Once RGA completes the Phase 1 Archaeological Survey, the Consultant will incorporate the draft report 
into TDOT’s Section 106 Assessment form template and submit the Section 106 Assessment to TDOT for 
review and comment. TDOT will submit the report to the TN-SHPO for review. 
Assumptions: 
▪ No Phase II Testing – If required, this work can be completed in accordance with the Additional 
Services clause of this agreement. 
▪ If a Memorandum of Agreement is needed to confirm agreed upon mitigation measures for the 
Build Alternative, it will be conducted in accordance with the Additional Services clause of this 
agreement. 
▪ If Phase III work, data recovery is necessary, it can be included in accordance with the Additional 
Services clause of this agreement. 
 
Environmental Justice 
Executive Order (EO) 14096 Revitalizing Our Nation’s Commitment to Environmental Justice for All  was 
revoked on January 20, 2025, and EO 12898 Federal Actions to Address Environmental Justice in Minority 
Populations and Low-Income Populations was revoked on January 21, 2025. Therefore, an environmental 
justice analysis is not proposed for this project. 
Farmland 
The project is in a designated urbanized area as indicated on the U.S. Census Bureau Urban Area 
Reference Map.  Therefore, the project is not subject to the Farmland Protection Policy Act. 
Hazardous Materials 
The Consultant will complete a desktop review of hazardous materials databases available through TDEC 
and the Environmental Protection Agency (EPA) to determine whether the proposed project area has the 
potential to contain hazardous materials that may be impacted by the project. This information along with 
all relevant TDEC and EPA database mapping for the project area will be presented in a memorandum, or 
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