Northeast Facilities Service Office
United States Postal Service

June 9 , 2005

Honorable Tom Gunderson, Mayor
Village of Aurora

RE: Relocation Proposed by the Village of Aurora New York
[Did our village government really propose this? Or was it the Foundation?]

Dear Mayor Gunderson:

The Northeast Facilities Service Office has received concept approval to proceed with the proposed relocation of the Aurora post office. Concept approval allows us to continue begin [sic] officially with the discussion and investigation of alternate locations, but does not provide funding or final approval for an actual relocation of the facility. The final approval will not be provided until a preferred site is located, cost estimates are developed, and other due diligence activities are completed.

An important next step for this project will be to meet with you and other appropriate local officials to discuss the postal facility requirements, and discuss the process by which the Postal Service will solicit and consider input from the affected community. Following that meeting, we will request placement on a village government public meeting agenda, so that the project can be described and discussed. ...

Sincerely,
Paul J. Senk
Manager, Real Estate

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

~~~~~

NORTHEAST FACILITIES SERVICE OFFICE
UNITED STATES POSTAL SERVICE

August 15, 2005

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.

I respectfully disagree with Mr. Farenthold concerning his statement that the Postal Service would "dump Aurora as a site for a post office." While it is true that there are features of the present facility that do not meet current design standards, and there are traffic safety concerns with the present location, leaving the community of Aurora is not an alternative under consideration.

Paul Senk
Manager, Real Estate

~~~~~

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 community 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

~~~~~

From: Senk, Paul J - Windsor, CT
Sent: Tuesday, September 20, 2005
To: Lord, Richard (SHPO)
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....

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.

8.) The SHPO concurs with the Aurora Coalition’s 11/24/04 opinion that Mr. Moncrief’s 10/12/04 attendance at a Village Board meeting did not fulfill the agency’s obligation to “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” [36 CFR 800.2(d)] because:

a) It was not well publicized or described as a public hearing;

b) It occurred during a Wells College break in this community where more than half the residents attend or work for the college.

9.) Given 36 CFR 800.2(d)’s emphasis on public participation (see 8 above) and levels of public interest, the SHPO cannot agree with any USPS conclusion that additional public hearings are not warranted: Aurora residents schedule a vehicular version of “musical chairs” in which private vehicles with bumper stickers, hand-painted slogans and even an electronic message board expressing displeasure with Foundation projects are parked continuously in front of the Foundation-run Aurora Inn. We know of no other community in New York State where this occurs.

10.) Information provided verbally by the Regional Office is sometimes at odds with that provided in written form: while Mr. Senk advised the SHPO in phone conversations that reuse of the existing Village-owned USPS facility was an option if deficiencies could be corrected, the 9/13/05 letter to the Mayor stated that “expansion of the existing facility must be eliminated from future consideration.” One week later Mr. Senk e-mailed the SHPO that “Expansion is still our first preference.” Unfortunately for preservationists, the letter to the Mayor is being used by some in the community to convince residents that a new location is a USPS requirement.

11.) Similarly, in e-mail exchanges among the SHPO, the Aurora Coalition and the Regional Office during summer of 2004, Mr. Senk advised that relocation would not be motivated by USPS requirements, that the USPS must follow a lengthy review process, and that a public hearing would be held. All that appears to have changed with the 9/13/05 letter to Mayor Gunderson.

12.) The existing post office is handicap accessible; the proposed site is not and would therefore not meet the mandate that federal agencies conform with the Americans with Disabilities Act (ADA).

The SHPO was concerned to learn that the Aurora Foundation had the 9/13/05 letter---and was asking residents to write letters of support---before it was received by Mayor Gunderson, to whom it was addressed. Mr. Senk acknowledged in conversations that he’d fielded a similar complaint.

The SHPO is also concerned that the agency’s stance has changed so dramatically in less than a year’s time. We were advised initially that the community and sponsor were driving this, that it would take many months and would require public hearings, and that there is no Section 106 review---yet.

With the 9/13/05 letter the USPS appears to be ready to move, ostensibly initiated Section 106 in March 2005 without contacting the SHPO or any other group that requested consulting party status, implies that there has been ample opportunity for public comment, and allows residents to weigh in by October 11 if they learn of the letter written to the Mayor and copied to the Postmaster. This 180-degree shift occurred after the Foundation’s benefactress indicated her offer would be withdrawn if not accepted by December 2005.

We have worked closely with Mr. Senk in the past and feel that we have a cooperative relationship and a fairly good understanding of each other’s concerns and procedures. Nonetheless, the proliferation of conflicting information, the very short deadline imposed by the sponsor, and the FPO’s seven-month silence are all troubling. The SHPO would like to ensure that the protection of historic resources receives every consideration, consistent with the provisions of the National Historic Preservation Act, and feels that the Council’s direct involvement would be productive.

We look forward to your response and thank you in advance for your assistance.

Sincerely,
Richard M. Lord
Historic Sites Restoration Coordinator

Enc: USPS 10/19/04 letter to SHPO
SHPO 11/19/04 letter to USPS
National Trust 11/24/05 letter to USPS
USPS 9/13/05 letter to Mayor Gunderson
9/19/05 SHPO e-mail to USPS and 9/20/05 response

Cc: Paul Senk, USPS Northeast Facilities, 6 Griffin Road North, Windsor CT 06006-0300
Elizabeth Merritt, National Trust for Historic Preservation
Tania Werbizky, Preservation League of New York State
Aurora Coalition

~~~~~

AURORA COALITION, INC.

Paul Senk, Real Estate Manager
USPS Northeast Facilities Office
6 Griffin Road North, Windsor CT 06006-0300

October 3, 2005

Dear Mr. Senk:

Pursuant to your letter to the Mayor of Aurora, NY dated September 13, 2005, we object to your decision to relocate our village post office without consultation, without accurate information, with-out media notification, without transparency, without a public hearing, without a timely Section 106 Review, and without faithful adherence to Postal Service Community Relations regulations.

1. In June 2004, you e-mailed me that “such a relocation would be motivated by the request of the Village of Aurora and not by the facilities requirements of the Postal Service.” On 9/13/05, you reversed position, writing Mayor Gunderson that “operational requirements cannot be met” at our present post office facility.

Your main concern in this regard is unfounded. The mail dispatch truck does not block the sidewalk during delivery and pick-up. The truck simply crosses the sidewalk as it moves in or out of the post office drive. My car crosses a sidewalk as I pull in or out of my own driveway. This is a common occurrence throughout the village. Given the normal precautions of any responsible driver, it presents no real “increased potential for pedestrian injury.”

In any event, the truck’s delivery and pick-up system was designed by the USPS and has been in use for nearly 30 years with no problem. Why cite it now as a reason to relocate?

2. Your letter of 9/13/05 also specifies “requirements” for more space and equipment, as if mail volume has exceeded the building’s capacity. But the USPS designed our current facility with excess capacity which is still unused. It appears that 239 boxes are not rented. A full wall of boxes -- about 30% of the total -- is covered with displays, unused by patrons. Why require more space and equipment now when the present facility is not fully utilized?

3. In December 2004, you wrote the regional attorney of the National Trust for Historic Preservation that you would be pleased to include her office “as a consulting party under Section 106 of the NHPA if and when an undertaking is initiated.” In the following nine months, you provided no hint to any interested party that an undertaking had been initiated. Now we find in your 9/05 letter to Mayor Gunderson that you claim this important step was taken back on March 10, 2005. Why was this information wihtheld?

4. On June 9, 2005, in asking Mayor Gunderson for a meeting with village officials, you wrote “following that meeting, we will request placement on a village government public meeting agenda, so that the project can be described and discussed.” On 9/13/05 you wrote our mayor that a public hearing would not be necessary. Why have you moved to eliminate public input?

5. In that same letter you state “expansion of the present facility must be eliminated from future consideration,” but the next week you e-mailed the State Historic Preservation Office that “expansion is still our first preference.” Why have you presented strikingly different positions to state and local officials?

6. Your letter of 9/13/05 gave the public 30 days to “object” to your decision, but it was not copied to any interested parties (as promised) nor published in the paper (as required). Though addressed to the Mayor, the letter reached the developer’s supporters before it was received in the Village Office. This led to its circulation with a flier and petition promoting the developer’s plans for our village, presented in such a way as to convince residents that the USPS requires relocation and demolition of our current post office. Why did the USPS facilitate this one-sided campaign by failing to copy all interested parties?

7. The Advisory Council for Historic Preservation has clarified Section 110 (k) of the NHPA by stating that: “a new provision directs Federal agencies to withhold... assistance to applicants who intentionally significantly and adversely affect historic properties. This provision, known as the ‘anticipatory demolition’ section, is designed to prevent applicants from destroying historic properties prior to seeking Federal assistance in an effort to avoid the Section 106 process.”

The developer altering our National Historic Register District avoided Section 106 Review and engaged in “anticipatory demolition” by partially gutting our 1901 School House -- its proffered site for a relocated post office -- and fully gutting and partly demolishing the 1833 Aurora Inn. The developer’s original plan to expand the inn’s parking lot (withdrawn to avoid a Section 106 Review triggered by the USPS lease on part of that lot) would be realized by the proposed post office relocation, following in the wake of willful, irreparable harm to our irreplaceable historic community resources.

Federal law prohibits federal agencies from granting assistance to developers who, in the language of Section 110(k), “intentionally significantly adversely affected a historic property.” Why is the USPS ignoring this prohibition in order to cooperate with just such a developer?

A single supposition could answer all seven questions above. One could suppose that a month after the developer set a deadline for acceptance of her relocation plan, the USPS abandoned community consultation and government regulations in order to collaborate with this controversial developer whose actions are strongly opposed by residents as well as state and national preservation groups.

Hoping to prove this supposition incorrect, we ask the USPS to reconsider its present course and restore a process of transparency and consultation, allowing for community access to accurate information, solicitation and consideration of public comment, and full observation of the National Historic Preservation Act under the guidance of the Advisory Council on Historic Preservation.

Thank you,

K.A. Hindenlang, VP
Aurora Coalition, Inc.
P.O. Box 334
Aurora NY 13026

www.geocities.com/auroracoalition

cc:
Don Klima, ACHP
Elizabeth Merritt, NTHP
Tania Werbizky, PLNYS

~~~~~

More Info on the P.O.

HOME