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Archive of Prominent Section 106 Cases:
April 1999

Alabama: Space Simulator

Arizona: Holbrook Interchange
(Woodruff Butte)

California: Gold Mine (Imperial County)

Colorado: KMM
Parking Structure
(Black Hawk)

Connecticut: New London Train Station

Washington, DC: World War II Memorial

Georgia: Federal Courthouse (Savannah)

Hawaii: Ewa Villages (Honolulu)

Wisconsin: Stillwater
Lift Bridge

Montana: Military Entrance Processing Station (Butte)

New Mexico:
El Rancho Electric Substation

Ohio: Buffington Island Sand and Gravel Mine

Pennsylvania: Gettysburg National Military Park

Virginia/Maryland: Woodrow Wilson Bridge

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Archive of Prominent Section 106 Cases:
April 1999

Colorado: Construction of KMM Parking Structure (Black Hawk)


On February 28, 1999, the Council executed a Memorandum of Agreement (MOA) that outlined measures to mitigate the adverse effects of the KMM Parking Project on the Central City/Black Hawk National Historic Landmark District. Mitigation measures called for in the MOA will be primarily off-site. They include the development of a signage program to interpret the history of Black Hawk and its landmark district to the general public, plus creation of a youth education program if any monies remain after the signage program. Investigation of the archeological significance of the project site is also provided for in the MOA.


In September 1998, the Council received a determination from the Corps of Engineers that the Central City-Black Hawk Historic District would not be adversely affected by issuance of a Section 404 permit for construction of a parking structure. The town of Black Hawk is one of three 19th-century mining towns in the mountains of Colorado with legal, limited stakes gambling. The historic district is a designated National Historic Landmark and is included on the “most endangered” lists of both the National Trust for Historic Preservation and Colorado Preservation, Inc. The proposed Main Street parking garage, which would serve adjacent casinos, would be five stories tall and about a block long.

In October 1998, the Council objected to the no adverse effect determination, agreeing with the Colorado State Historic Preservation Office (SHPO) that the proposed project was out of character with the scale of the historic district. The Council also based its objection on the project’s potential to change the historic configuration of Main Street, alter the natural topography and environment of the district, and contribute to further development pressures.

Policy Highlights

Of the three historic mining towns in Colorado where gambling is legal, Black Hawk has been changed by the gaming industry most dramatically. Black Hawk has lost many of its historic properties, and numerous large-scale casino buildings have been built in their place. Black Hawk’s wooded mountain setting, which is tied to its identity as a mining community, also is being altered significantly.

Traditional historic preservation policies and approaches are challenged by the realities of Black Hawk’s gaming-dependent economy, the town’s radical transformation, and the fragile survival of its remaining historic properties. Therefore, meetings among the consulting parties focused on whether adverse effects should be mitigated off-site, rather than through design changes to this individual project. The consulting parties agreed that off-site mitigation would enhance the public’s knowledge of the history of Black Hawk and the significance of the landmark district, while acknowledging the dynamic nature of the town’s development.

Staff contact: Marjorie Nowick

October 1998 report on this case

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