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Archive of Prominent Section 106 Cases:
June 2000


Criteria for

Hoover Dam Bypass

U.S. Courthouse
(San Diego)

Geothermal Developments
(Modoc & Klamath National Forests)

District of Columbia:
General Post Office

South Lawrence Trafficway

Industrial Canal Lock
(New Orleans)

Stillwater Lift Bridge

U.S. Courthouse

New York:
Hudson River Park
(New York City)

South Dakota:
Francis Case Reservoir

South Dakota:
Federal Lands along Missouri River

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District of Columbia:
Leasing of General Post Office Building

Agency: General Services Administration

Criteria for Council Involvement:

  • The General Post Office is a highly significant National Historic Landmark in the nation's capital (Criterion 1).

  • The project may set precedent regarding Section 106 review of leases under Section 111 of the National Historic Preservation Act (Criterion 2).

  • Initially, the project generated substantial public controversy (Criterion 3).

Recent Developments

Consultation under Section 106 during the past two years has been marked by an extraordinary level of cooperation among the consulting parties. Lengthy discussions about the scope of the undertaking, the identification of character-defining spaces and features, and myriad design issues have been addressed successfully.

Under the terms of the lease, GSA will undertake a $5 million program of repair and restoration of the building’s exterior, including repairing the historic windows. The developer reportedly will invest $32 million in its interior renovation program.

General Post Office Building, Washington, DC

General Post Office Building, Washington, DC (photo courtesy of Mary Oehrlein)

In the very near future, the Council will complete the Section 106 review for the project with a Memorandum of Agreement (MOA). Basic agreement on key elements of the MOA has been reached and final details are being negotiated. The MOA will outline how further review of the project’s design will proceed.


The National Capital Region of GSA is leasing the General Post Office Building to a private developer pursuant to the leasing authority granted in Section 111 of the National Historic Preservation Act (NHPA). The General Post Office Building, known locally as the US Tariff Commission Building, is a National Historic Landmark.

It was the first significant Federal building constructed in Washington, DC after the US Capitol and the White House. Construction began on the finely detailed neoclassical building in 1839 pursuant to the design of Robert Mills. Expanded and completed in 1866 by Thomas U. Walter, one of the architects of the Capitol, the building served as the main post office for the city from 1841 to 1899. It was the site of the first public telegraph office in 1845 and was used as a hospital during the Civil War.

The General Post Office retains an extraordinary level of physical integrity for a building of its age and use, and this posed a challenge to GSA in planning its reuse. GSA reached its decision to lease the building after multiple analyses completed over a period of several years demonstrated the difficulty—and cost—associated with the government rehabilitating the building for either office use or museum space, while respecting the building’s integrity.

GSA undertook a vigorous and broad-ranging program of public involvement in the initial decision-making process for the lease. It gave historic preservation issues greatest weight in its analysis of the proposals it received and actively involved the Council and the District of Columbia State Historic Preservation Office in the review and comment process.

In early 1998, GSA selected the Kimpton Hotel Group as the successful bidder for the lease. The company plans to convert the building to a 180-room “boutique” hotel. GSA’s selection of this use for the property was initially not well-received by residents of the immediate neighborhood, who had hoped that the building would be used for residences.

In making this selection, however, GSA recognized that conversion of the property to a hotel would involve far less intrusive alterations to the building than residential or office use. Use as a hotel also means that the building and its significant spaces will remain open to the public.

Policy Highlights

After numerous funding requests to Congress for an appropriate rehabilitation program for the building were unsuccessful, GSA turned to the leasing authorities of Section 111 of the NHPA. Section 111 permits Federal agencies to lease historic buildings and, importantly, to retain revenue from such leases to defray historic preservation costs.

In this case, it is estimated that approximately $50 million will be generated over the 60-year life of the lease for GSA’s use in maintaining this historic property and others in its portfolio. GSA’s efforts serve as a useful model for the implementation of Section 111, an underutilized tool for improving stewardship of Federally-owned historic properties.

Staff contact: Ralston Cox

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