2-2-2026: RE: Request for Section 106 Consultation - EDA Grant Award No. 08-79-05667 to New Orleans Jazz Museum, Old U.S. Mint National Historic Landmark, 400 Esplanade Ave., New Orleans, LA

February 2, 2026

Corey Dunn – cdunn@eda.gov
Civil Engineer & Regional Environmental Officer
Austin Regional Office
Economic Development Administration
U.S. Department of Commerce
903 San Jacinto Blvd., Suite 206
Austin, TX, 78701

RE: Request for Section 106 Consultation - EDA Grant Award No. 08-79-05667 to New Orleans Jazz Museum, Old U.S. Mint National Historic Landmark, 400 Esplanade Ave., New Orleans, LA

Dear Mr. Dunn:

Louisiana Landmarks Society is writing to request that the Economic Development Administration convene a formal Section 106 consultation session prior to the continuation of any work on the proposed outdoor music stage project at the New Orleans Jazz Museum, located at the Old U.S. Mint, a National Historic Landmark (NHL). This stand-alone NHL building is located within New Orleans’ Vieux Carré Historic District, which itself was designated an NHL District in 1965.

We understand that the State Historic Preservation Officer (SHPO) issued a “no adverse effect” finding for the Old Mint NHL, dated June 4, 2025, but we believe this determination was premature, did not solicit pre-decisional comments from recognized preservation and neighborhood stakeholders and thus lacked any meaningful input from the public, and failed to adequately consider significant, negative impacts that this federally funded undertaking will have on historic properties other than the Old Mint, especially the surrounding Vieux Carré NHL District. Specifically, the review process did not address:

1. NOISE AND RELATED SOUND IMPACTS: The installation of a permanent outdoor stage/music venue (referred to in the submitted project plans as “performance stage area with lawn” and/or “event lawn and stage”) will introduce ongoing amplified sound levels into a National Historic Landmark and the surrounding National Landmark Historic District. The cumulative effect of regular performances on the historic character, residential use, and visitor experience of these properties was not evaluated in a Section 106 review.

2. TRAFFIC AND CIRCULATION IMPACTS: The proposed venue will generate increased vehicular and pedestrian traffic in the already over-trafficked historic district. Changes to traffic patterns, parking demands, pedestrian movement, and street usage were not considered as potential effects on the historic district’s setting and streetscape.

3. CUMULATIVE EFFECTS: Because a full Section 106 review was not conducted, any EDA reviews failed to consider this project in conjunction with the concurrent development of the riverfront park at the Esplanade and Governor Nicholls Street wharves, where a music stage is already under construction. Along with their adjacency to the highly commercialized Frenchmen Street entertainment area, the combined impact of multiple music venues in close proximity within the historic district represents a fundamental change to the area’s character.

4. INCOMPLETE PROJECT INFORMATION: Future plans (Phase II) for the riverfront park development have not been revealed, making it impossible to adequately assess the cumulative effects of related federal undertakings on historic properties as required under Section 106.

5. PUBLIC NOTICE AND INPUT: No public notice or input opportunity was provided.

As you know, the National Historic Preservation Act requires federal agencies to take into account the effects of their undertakings on historic properties and afford the Advisory Council on Historic Preservation and other consulting parties a reasonable opportunity to comment; this is known as the Section 106 consultation process, the details of which are set forth in the regulations of the Advisory Council on Historic Preservation, 36 CFR Part 800.

We also note that your agency has its own “Environmental Narrative Template” (rev. Mar. 2025) for grant applicants, which requires notice and consideration of a proposed project’s possible environmental impacts. Concerning “HISTORIC/ARCHEOLOGICAL RESOURCES,” EDA’s template requires an applicant to

Identify any known historic/archeological resources within the project sites(s) or area of potential effect that are either listed on the National Register of Historic Places or considered to be of local or State significance… Delineate an Area of Potential Effect (APE) for the project. The APE is the geographic area or areas within which a proposal may cause change in the character or use of historic properties, which would include (but is not limited to) any new development or renovation by the beneficiary facilitated by the propoproposed EDA project. Discuss the potential impacts of the project on culturally significant resources….

For any possible “Noise” concerns, EDA’s template asks, “Would operation of project facilities or primary beneficiaries’ facilities increase local ambient noise levels? If yes, indicate the estimated levels of increase, and the areas and sensitive receptors (e.g., residences, wildlife) to be affected.”

Regarding “Public Notification/Controversy,” EDA also requires its applicants to “[p]rovide evidence of the community’s awareness of the project, such as newspaper articles or public notification and/or public meetings, as applicable.”

The current review process has not met these requirements.

We respectfully request that EDA:

• Initiate a formal Section 106 consultation process with all appropriate consulting parties before the continuation of any further ground disturbance or construction activities;
• Expand the APE and assessment of effects to include ongoing operational impacts such as sound, traffic, and changes to the Vieux Carré historic district’s residential character;
• Conduct a cumulative effects analysis that considers this project in conjunction with the riverfront park development and other planned or ongoing projects in the area;
• Ensure that all relevant project information and future plans are disclosed publicly to allow for meaningful consultation;
• Provide adequate public notice and give a full opportunity for consulting parties and interested stakeholders to participate in the consultation process.

As historic cities of the world struggle to address the negative impacts of overtourism, the Old U.S. Mint as a National Historic Landmark and the Vieux Carré, a National Historic Landmark District, represent irreplaceable cultural resources. A long-recognized factor in what makes this Historic District unique is that it is a living, breathing residential neighborhood. The introduction of permanent outdoor music venues and the associated operational impacts warrant thorough analysis and consultation before federal funds are committed and construction continues.

We appreciate your prompt attention to this matter and look forward to participating in a comprehensive Section 106 consultation process.

Respectfully submitted,

Sandra L. Stokes

James R. Logan, IV

cc: Kelly Fanizzo, General Counsel, Advisory Council on Historic Preservation - kfanizzo@achp.gov Rachel Mangum, Advisory Council on Historic Preservation – rmangum@achp.gov Robert Peche, Economic Development Representative, Economic Development Administration, US Department of Commerce – rpeche1@eda.gov Cynthia Walton, Branch Manager, Archeological and Historic Preservation Partnerships, National Park Service, Interior Region 2 – cynthia_walton@nps.gov David Poche, Facility Planning and Control, Louisiana Division of Administration - david.poche@la.gov Carrie Broussard, Louisiana State Historic Preservation Officer - cbroussard@crt.la.gov Nicole Hobson-Morris, Executive Director, Louisiana State Historic Preservation Office – nmorris@crt.la.gov Betsy Merritt, Deputy General Counsel, National Trust for Historic Preservation - emerritt@savingplaces.org Nathan Chapman, President, Vieux Carre’ Property Owners & Residents Association (VCPORA) nathanechapman@gmail.com