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Mr. BJ Leithead Todd LOG NO: 2010.0254 Page 2 DOC NO: 1001 STO8 Although given a "Marginal" rating of significance (possibly due to its age being less than 50 years at the time of the survey, January 1974), we believe that the residence may have increased significance since the survey was completed given its current considerable age (80+ years old). Therefore we believe that the residence is eligible for listing on the National Register of Historic Places under Criteria C ( "that embodies the distinctive characteristics of a type, period, or method of construction, or that represents a significant and distinguishable entity whose components may lack individual distinction "). The proposed work for this project constitutes an "effect to historic properties," as such, proper measures will need to be taken to document the historic property, determine its historic significance, and appropriate mitigation commitments need to be met. Before work on this project may commence an architectural survey needs to be completed: "Minimally, information shall be of sufficient quality to complete a National Register of Historic Places nomination form. The survey must be directed by a qualified historian, architect, or architectural historian who meets the qualifications set forth in chapter 13 -281 (§13-284 (HAR))." As this project will affect historic properties, mitigation commitments need to be established and carried out. Accepted forms of mitigation include: preservation, architectural recordation, archaeological data recovery, historic data recovery, and ethnographic documentation. Commitments necessary to mitigate the effects of this particular project on historic properties include: "architectural recordation plans meeting the minimal standards as provided by historic American building survey (HABS) photographic specifications; (and/or) preservation plans meeting the minimal standards as provided by chapter 13 -277 and the Secretary of the Interior's standards for historic preservation projects." The appropriate form of mitigation will be determined based on an assessment of the submitted additional information requested. A completion report that accomplishes the agreed -upon mitigation commitments must be approved by SHPD before the historic preservation review process can be concluded. Work may begin on the proposed project once the mitigation commitments proposed in this letter have been agreed to. SHPD must be contacted in writing to inform us of the agreement to carry out the mitigation commitments once they are determined. Thank you for the opportunity to comment. Should you have any questions regarding architectural concems,.please call Susan Tasaki at (808) 692 -8015. i 'Sincerely, kag Puaalao alani Aiu, Ph.D. Administrator c: Theresa Donham, SHPD Archaeology, Island of Hawaii