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U.S. Department of Homeland Security Federal Emergency Management Agency DR-4335-VI and DR-4340-VI 81 CC & DD Kronprindsen Gade Charlotte Amalie, St. Thomas 00802 February 1, 2018 Sean L. Krigger Acting Director/Deputy State Historic Preservation Officer Department of Planning and Natural Resources Virgin Islands State Historic Preservation Office 1640 Dronningens Gade 71&72A, Kongens Quarter Charlotte Amalie, Virgin Islands 00802 Re: Determination of Eligibility, Public School Buildings on St. Thomas and St. John for potential Federal Emergency Management (FEMA) Undertakings under DR-4335-VI and DR- 4340-VI (Hurricanes Irma and Maria) Location: 15 Public Schools on St. Thomas and St. John, USVI Dear Mr. Krigger: The Federal Emergency Management Agency (FEMA) will be providing funds authorized under the Robert T. Stafford Disaster Relief and Emergency Assistance Act, P.L. 93-288, as amended, in response to major Disaster Declarations FEMA-4335-DR-USVI, dated September 7, 2017 and FEMA-4340-DR-USVI, dated September 20, 2017. As a result of Hurricanes Irma and Maria, FEMA is aware of extensive damage to the public schools located on St. Thomas and St. John, USVI, and acknowledges the likelihood of the Department of Education on both islands seeking FEMA Public Assistance funding to repair the schools. FEMA prepared this Determination of Eligibility (DOE) for all St. Thomas and St. John public schools in order to streamline future project reviews. Methodology The Department of Education currently oversees 15 public school buildings and complexes used for the education of children living in the St. Thomas and St. John school district. The Department of Education owns additional buildings and there are a number of private schools on St. Thomas/St, John. This Determination of Eligibility is limited to public schools. For schools deemed Eligible for listing on the NHRP FEMA will: o continue to consult with SHPO in the event proposed work does not meet Programmatic Allowances as detailed in Appendix B of FEMA’s Virgin Islands Programmatic Agreement executed on July 14, 2016; o follow the protocols as described in Stipulation II: Project Review, and may choose to

Transcript of DR-4335-VI and DR-4340-VI Charlotte Amalie, St. Thomas 00802 · Charlotte Amalie, St. Thomas 00802...

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U.S. Department of Homeland Security Federal Emergency Management Agency

DR-4335-VI and DR-4340-VI 81 CC & DD Kronprindsen Gade Charlotte Amalie, St. Thomas 00802

February 1, 2018

Sean L. Krigger Acting Director/Deputy State Historic Preservation Officer Department of Planning and Natural Resources Virgin Islands State Historic Preservation Office 1640 Dronningens Gade 71&72A, Kongens Quarter Charlotte Amalie, Virgin Islands 00802

Re: Determination of Eligibility, Public School Buildings on St. Thomas and St. John for potential Federal Emergency Management (FEMA) Undertakings under DR-4335-VI and DR- 4340-VI (Hurricanes Irma and Maria) Location: 15 Public Schools on St. Thomas and St. John, USVI

Dear Mr. Krigger:

The Federal Emergency Management Agency (FEMA) will be providing funds authorized under the Robert T. Stafford Disaster Relief and Emergency Assistance Act, P.L. 93-288, as amended, in response to majorDisaster Declarations FEMA-4335-DR-USVI, dated September 7, 2017 and FEMA-4340-DR-USVI, datedSeptember 20, 2017.

As a result of Hurricanes Irma and Maria, FEMA is aware of extensive damage to the public schools located on St. Thomas and St. John, USVI, and acknowledges the likelihood of the Department of Education on both islands seeking FEMA Public Assistance funding to repair the schools. FEMA prepared this Determination of Eligibility (DOE) for all St. Thomas and St. John public schools in order to streamline future project reviews.

Methodology

The Department of Education currently oversees 15 public school buildings and complexes used for the education of children living in the St. Thomas and St. John school district. The Department of Education owns additional buildings and there are a number of private schools on St. Thomas/St, John. This Determination of Eligibility is limited to public schools.

For schools deemed Eligible for listing on the NHRP FEMA will:o continue to consult with SHPO in the event proposed work does not meet Programmatic

Allowances as detailed in Appendix B of FEMA’s Virgin Islands ProgrammaticAgreement executed on July 14, 2016;

o follow the protocols as described in Stipulation II: Project Review, and may choose to

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consult or notify SHPO if the Undertaking is extensive, meets several Programmatic Allowances, or in order to exhibit “good faith;”

o attach this letter and SHPO’s response to the project Record of EnvironmentalConsideration (REC).

For schools deemed Not Eligible for listing on the NRHP:o FEMA will apply the applicable Programmatic Allowances as detailed in Appendix B of

FEMA’s Virgin Islands Programmatic Agreement executed on July 14, 2016; note thatOther Program Activities (Allowance Tier II: F.2.a) addresses repair, retrofit or renovationof buildings determined ineligible within the last five years;

o attach this letter and SHPO’s response to the project REC.

At the time of this document’s writing, the Department of Planning and Natural Resources (DPNR) has not issued a finding of condemnation for any of the 15 schools damaged as a result of the Hurricanes Irma and Maria.

Historic contexts for 20th century architectural styles and educational institutions for the USVI are limited. Research for this document consisted of primary and secondary historic resources including written documents and maps. “Brief Historical Notes on Schools of the Virgin Islands” was a valuable resource. Analysis of school buildings was largely drawn from comparison of historic map information to current building configurations. FEMA EHP assessed and photographed the 15 school complexes from public right of ways looking for potential significance, integrity, and alterations.

Study Area The study area consists of all known public schools located within the St. Thomas/St. John school district within the United States Territory of the Virgin Islands. Campuses and complexes consist of buildings within each individual school property boundary. For the purpose of this DOE, only the above ground resources were evaluated; if in the future FEMA receives requests for undertakings involving ground disturbing activities, then additional consultations will be initiated with the SHPO.

Historic Context

There is currently minimal historic context written about the educational system in the USVI and no historic context of 20th century architecture. For the purposes of this DOE, Modern Style was predominately popular between c.1920 – c. 1970. Architectural features include minimal decorations, emphasis on horizontal lines, and streamlined forms and shapes common in the USVI.

The schools included in this evaluation consist of similar architectural styles and construction periods. Of the 15 schools evaluated, 11 exhibit the Modern Style. Many of the original 17th century mission schools are no longer standing, but some locations, such as the Leonard Dober Elementary School, were reconstructed within the same footprint of the original school. Presently, all but Leonard Dober Elementary School were constructed in the latter half of the 20th century. The increase in schools in the 20th century is partly due to the growing interest in stronger educational standards across the United States and the Virgin Islands after the Great Depression. Inventory of Resources

Addelita Cancryn Junior High School Addelita Cancryn Junior High School, constructed c. 1960 is located at 1 Crown Bay, situated between Crown Bay and Frenchtown, St. Thomas. The school complex has 16 buildings constructed in the Modern Style laid out to create a square central courtyard. All buildings are constructed of CMUs. The main building is two stories high with a hipped roof. The two levels are visually differentiated on the primary façade. The

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upper level is comprised completely of fixed-sash aluminum windows, while the lower is concrete decorated with repetitive geometric patterns flanking the main entrance. Flanking the primary building are three rows of one-story hipped roof buildings connected by flat-roof sheltered walkways. Three buildings are located at the rear of the complex also with hipped roofs and aluminum fixed-sash windows.

Bertha C. Boschulte Middle School Constructed in 2002-2003, Bertha C. Boschulte Middle School is located at 9-1 & 12A Bovoni Road in Estate Bovoni, St. Thomas. The complex features 13 buildings and are arranged in an “L” shape. The buildings are predominantly two-story, combination-roofed, buildings constructed of CMU and featuring fixed-sash aluminum windows. The primary entrance features an enclosed arched walkway supported by metal posts.

Charlotte Amalie High School Charlotte Amalie High School, constructed in 1955 with an addition constructed c. 1983, is located in the colloquially known “town area” at 8-9 Estate Thomas, St. Thomas. The 32-building complex consists of three linear rows of three-story, flat-roofed, Modern Style, CMU buildings with fixed-sash aluminum windows. The buildings to the east of the school proper are also CMU but have gabled roofs. The primary entrance is located at the southern end of the complex in a hexagonal-shaped building with a flat roof and fixed sash six-over-six light windows.

E. Benjamin Oliver Elementary SchoolE. Benjamin Oliver Elementary School, constructed in 1976, is located at 148 325 Anna’s Retreat, St.Thomas. The complex consists of 15 buildings stemming from one central building. The main building isa flat-roofed, Post Modern Style, CMU building with fixed-sash aluminum windows and a two-story arcadeadorned with metal gates. A covered walkway leads from the central building to a radial walkway fromwhich three building groupings stem. The groupings are each comprised of five buildings positioned atangles to create two triangular courtyards.

Gladys A. Abraham Elementary School Gladys A. Abraham Elementary School, constructed between 1965 and 1983, is located at 68A Estate Lindberg, St. Thomas. The complex consists of an auditorium building, administrative offices, and two sets of classroom pods, each of which have four buildings. The main building consisting of office space and an auditorium is a flat-roofed, Modern Style, CMU building with fixed-sash aluminum windows. A covered walkway attached to the east elevation leads to the two classroom pods. Each building within the pod is a one-story, gabled-roof, CMU building with fixed-sash aluminum windows. Covered walkways connect all of the pod buildings.

Guy H. Benjamin Elementary School Guy H. Benjamin Elementary School, constructed in 1975, is located at 1 2 Emmanus, Coral Bay, St. John. The school complex consists of seven buildings, all of which are corrugated metal gable-roofed CMU buildings with underlying plywood sheeting. The Modern Style buildings have fixed-sash aluminum windows and are of uniform design throughout. Guy H. Benjamin Elementary closed in 2014 due to low enrollment. Ivanna Eudora Kean High School Ivanna Eudora Kean High School, constructed in 1971, is located within the “countryside” area of St. Thomas and services the East End, Southside and Northside districts. Along Route 32 at 1-2 Estate Nazareth. The High School has 25 buildings laid out in an “L” shape. The main building, located closest to Route 32, is a two-story, gable-roof, Modern Style, CMU building with fixed-sash aluminum windows. The main building opens to two rows of classroom buildings through a series of covered walkways. The remainder of the buildings in the complex, save for the gymnasium, are constructed like the main building. The gymnasium, constructed c. 1990, was constructed with a gabled roof and

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fixed windows topped with a triangular skylight. The gymnasium also features semi-circular protrusions on the primary façade. Jane E. Tuitt Elementary School Jane E. Tuitt Elementary School, constructed in 1959, is located at 19 Levoki Straede, St. Thomas, on the outskirts of the National Register-listed Charlotte Amalie Historic District (NR #76001860), St. Thomas. The campus consists of eight buildings and includes an annex, an “L” shaped main building, main office, and cafeteria. All buildings in the complex are either one or two-story, gable-roof, Modern Style, CMU buildings with fixed-sash aluminum windows. A painted mural adorns the primary façade of the main building.

Joseph A. Gomez Elementary School Joseph A. Gomez Elementary School, constructed in 1970, is located at 142 Anna’s Retreat in the Anna’s Retreat neighborhood of St. Thomas. The school complex has 12 buildings split into two distinct clusters. The northern cluster of buildings is made up of long, rectangular classroom buildings and a main building accessed from Kongens Gade. The second cluster of buildings appear to be offices and miscellaneous spaces. All buildings within the complex are one or two-story, with combination-roofs, constructed in the Modern Style of CMUs with fixed-sash windows.

Joseph Sibilly Elementary School Joseph Sibilly Elementary School, constructed in 1973, is located at 14 15 16 Estate Elizabeth, St. Thomas. The school complex has 11 buildings. The classroom buildings are two-story, combination-roof, Modern Style, CMU buildings with fixed-sash windows. The office buildings are one-story, but maintain similar architectural features.

Julius E. Sprauve Elementary School Julius E. Sprauve Elementary School, constructed in 1957, is located at 14-18 Enighed, situated directly outside of the boundaries of Cruz Bay Historic District (NR: #16000699), St. John. The school’s main complex is laid out in an “L” shape adjacent to the J.E.S.S. Ball Park. Two additional buildings are located across the street at both Enighed Provisional Road 41 and Fishfry Road. The school buildings are rectangular, two-story, flat or gable-roof, Modern Style buildings constructed of CMU’s with fixed-sash aluminum windows.

Leonard Dober Elementary School Leonard Dober Elementary School, constructed in the late 1930s, is located at 9A-10B Kropindsens Gade in the southwest quadrant of Charlotte Amalie Historic District (NR #76001860), St. Thomas. The school consists of five buildings; three of the five buildings were either not in use or owned by the Virgin Islands Department of Education prior to the hurricane. The main building is an “L” shaped, two-story, corrugated flat-roof, Modern Style building constructed of CMU with fixed-sash aluminum windows. The first floor features Doric columns supporting the second floor balcony. Building two is located on a southeast diagonal from the main building. Building two, the cafeteria, is an unadorned CMU building with a gable roof. The current Leonard Dober Elementary School has been modified since its construction. The first story of the main building was constructed c. 1930; the second floor and additional buildings were added in the 1960s. Lockhart Elementary School Lockhart Elementary School, constructed in 2000, is located at 41 Estate Thomas, Charlotte Amalie, St. Thomas, immediately east of Charlotte Amalie High School. Fourteen buildings make up the school complex. They are arranged in a trapezoidal footprint framing a central courtyard. The main entrance is located beneath a recessed archway in the first building directly off of Perimeter Road and has a gabled roof. The remaining 13 buildings appear to be one-story, flat-roof, CMU buildings with fixed-sash aluminum windows. The same unadorned arch found on the primary façade of the main entrance can be seen throughout the complex.

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Ulla F. Muller Elementary School Ulla F. Muller Elementary School, constructed in 1979, is located at 7B Estate Contant, St. Thomas. The complex consists of ten buildings arranged in a sideways “U” shape. The buildings in the complex are one-story, gable-roof, Modern Style, CMU buildings with fixed-sash aluminum windows and extended roof overhangs. Many of the buildings also have low retaining walls constructed of stone and concrete along the primary façade.

Yvonne E. Milliner-Bowsky Elementary School Yvonne E. Milliner-Bowsky Elementary School, constructed in 2000, is located at 15B – 16 Estate Mandahl on the Northside of St. Thomas. Eight buildings make up the school complex. They are arranged in a manipulated triangle footprint. The main entrance is located beneath a recessed archway and features a gable roof. A simple, shallow arch frames the main door. The remaining classroom buildings are two-story, gable-roof, constructed of CMU with fixed-sash aluminum windows.

Evaluation

Leonard Dober Elementary Leonard Dober Elementary School is located within the southwest quadrant of the Charlotte Amalie Historic District. The original Leonard Dober School was a private school operated by the Moravian missionaries in the 18th century. Leonard Dober was one of the first two Moravian missionaries to visit the Danish West Indies with the aim of Christianizing and educating the enslaved on St. Thomas. Dober’s main objective on St. Thomas was to convert enslaved peoples, but he lived frugally and with no income. He was hired as a steward in the home of the Governor; however, his work with the enslaved was viewed as suspicious especially during the insurrection of St. Croix. He eventually left his job with the Governor and became an estate watchman. Years later, Dober was elected as an Elder of the Moravian Brethren and left St. Thomas.1

The original Leonard Dober School was later closed due to over-crowding and poor social conditions in the area. The school was reopened many years later and renamed the Ulysses Grant School in honor of the 18th president of the United States. This school was eventually closed and used as a church. The date of demolition is unknown. There do not appear to be any extant remnants of the original building.

The construction date of the current school, 1930s, falls outside of the period of significance of the Charlotte Amalie Historic District, which is documented as three centuries long beginning in 1600 and ending in 1900. The school itself is not the work of a master and does not possess high artistic value. It additionally is not listed as a contributing building to the Charlotte Amalie Historic District and has lost integrity of design due to extensive construction and expansion in the mid- to late-20th century. Therefore, FEMA has determined that the Leonard Dober Elementary School is not eligible for listing in the NRHP under Criterion C.

Schools not eligible due to lack of significance Addelita Cancryn Junior High School; constructed c. 1960s Charlotte Amalie High School; constructed c. 1955 Gladys A. Abraham Elementary School; constructed c. 1965-1983 Ivanna Eudora Kean High School; constructed c. 1971 Jane E. Tuitt Elementary School; constructed c. 1959

1 Ruth Moolenaar, “Brief Historical Notes on Schools of the Virgin Islands,” Project Introspection, Virgin Islands, 1982 p. 6.

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Joseph A. Gomez Elementary School; constructed c. 1970 Julius E. Sprauve Elementary School; constructed c. 1957

The above listed schools do not represent the work of a master, possess high artistic values, or represent a significant and distinguishable entity whose components exhibit individual distinction for listing on the NRHP. In addition, the surrounding respective neighborhoods of each of these schools do not retain the level of integrity and/or age requirement to be considered a historic district per National Park Service guidelines. Therefore, the schools could not be contributing elements within designated historic districts. While these buildings fall within the age requirement for listing on the NRHP or will likely meet the age requirement while long term recovery efforts are underway for Hurricanes Maria and Irma; they lack sufficient historic significance for consideration. As such, FEMA has determined that they are Not Eligible for listing on the NRHP under Criterion C.

Schools not eligible due to age Bertha C. Boschulte Middle School, constructed in 2002-2003. E. Benjamin Oliver Elementary School, constructed in 1976. Guy H. Benjamin Elementary School, constructed in 1975 Joseph Sibilly Elementary School, constructed in 1973 Lockhart Elementary School, constructed in 2000. Yvonne E. Milliner-Bowsky Elementary School, constructed in 1979. Ulla F. Muller Elementary School, constructed in 2000.

These properties are less than 50 years in age and therefore do not meet the age consideration for listing on the NRHP. They do not appear to be of exceptional significance thereby meeting Criterion Consideration G. FEMA has determined, for the purposes of DR-4335 and DR-4340 that these schools are Not Eligiblefor listing on the NRHP under Criterion C. Should events or appropriate age be achieved at a later date,reevaluation of these schools may be necessary.

We request concurrence with this determination of eligibility within 15 calendar days. Should you need additional information please contact Ms. Shauna J. Haas, Historic Preservation Specialist by email at [email protected] or by phone at (202) 718 2343.

Sincerely,

Mark M. Soeth Environmental Historic Preservation Advisor

SH/cs

enc: Map Index_STT/J Public Schools Photo Index_STT/J Public Schools

Inventory of Resources_STT/J Public Schools

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Figure 1: Addelita Cancryn Junior High School property boundary indicated by blue lines.

Figure 2: Bertha C. Boschulte Middle School property boundary indicated by blue lines.

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Figure 4: E. Benjamin Oliver Elementary School property boundary indicated by blue lines.

Figure 3: Charlotte Amalie High School property boundary indicated by blue lines.

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Figure 5: Gladys A. Abraham Elementary School property boundary indicated by blue lines.

Figure 6: Guy H. Benjamin Elementary School property boundary indicated by blue lines

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Figure 7: Ivanna Eudora Kean High School property boundary indicated by blue lines.

Figure 8: Jane E. Tuitt Elementary School property boundary indicated by blue lines.

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Figure 9: Joseph A. Gomez Elementary School property boundary indicated by blue lines.

Figure 10: Joseph Sibilly Elementary School property boundary indicated by blue lines.

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Figure 11: Leonard Dober Elementary School property boundary indicated by blue lines.

Figure 12: Leonard Dober Elementary School property boundary indicated by blue lines.

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Figure 13: Figure 13: Lockhart Elementary School property boundary indicated by blue lines.

Figure 14: Ulla F. Muller Elementary School property boundary indicated by blue lines.

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Figure 15: Yvonne E. Milliner-Bowsky Elemenatary School property boundary indicated by blue lines.

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Photo 1: Addelita Cancryn Junior High School facing south.

Photo 2: Bertha C. Boschulte Middle School facing north.

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Photo 3: Charlotte Amalie High School facing north.

Photo 4: E. Benjamin Oliver Elementary facing south west.

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Photo 5: Gladys A. Abraham Elementary School facing west.

Photo 6: Guy H. Benjamin Elementary School facing south.

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Photo 7: Ivanna Eudora Kean High School facing north west.

Photo 8: Jane E. Tuitt Elementary School facing north west.

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Photo 9: Joseph A. Gomez Elementary School facing north east.

Photo 10: Joseph Sibilly Elementary School facing north west.

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Photo 11: Julius E. Sprauve Elementary School facing south west.

Photo 12: Leonard Dober Elementary School facing southwest.

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Photo 13: Lockhart Elementary School facing west.

Photo 14: Ulla F. Muller Elementary School facing northwest.

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Photo 15: Yvonne E. Milliner-Bowsky Elementary School

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Resource Number

School Name

Address Construction

Date Architectural

Style Photograph

1.

Addelita Cancryn High School

1 Crown Bay, St. Thomas, VI c. 1960s

Resource

Modern Style

2.

Bertha C. Boschulte Middle School

9 1 & 12A Bovoni, St. Thomas, VI c. 2002-2003

Post- Modern Style

3.

Charlotte Amalie High School

8 & 9 Estate Thomas, St. Thomas, VI c. 1955

Modern Style

4.

E. Benjamin Oliver Elementary School

148 325 Anna’s Retreat, St. Thomas, VI c. 1976

Post-Modern Style

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Resource School Construction Architectural Address Photograph

Number Name Date Style

Yvonne E. 15B & 16 Milliner- Estate Bowsky Mandahl, Elementar St. Thomas, Post Modern

15. y School VI c. 2000 Style Resource

Addelita Cancryn 1 Crown High Bay, St. Modern

1. School Thomas, VI c. 1960s Style

Bertha C. Boschulte 9 1 & 12A Post- Middle Bovoni, St. Modern

2. School Thomas, VI c. 2002-2003 Style

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DEPARTMENT OF PLANNING AND NATURAL RESOURCES Virgin Islands State Historic Preservation Office

Fort Frederik National Historic Landmark Site Strand Street 198, Frederiksted St. Croix, Virgin Islands 00840

Telephone: (340) 719-7089 Facsimile: (340) 719-8343

February 28, 2018

Mr. Mark M. Soeth EHP Advisor and Manager DR4340

Ref: VISHPO Review on the Determination of Eligibility, Public School Buildings on St. Thomas & St. John, Virgin Islands USA for potential Federal Emergency Management (FEMA) Undertakings under DR-4335-VI and DR-4340-VI (Hurricanes Irma and Maria) Location: 15 Public Schools on St. Thomas & St. John, VI

Dear Mr. Soeth:

The Virgin Islands State Historic Preservation Office (VISHPO) has reviewed the Federal Emergency Management's (FEMA) submittal package on the determination of eligibility for the 15 Public Schools under the Virgin Islands Department of Education that may be considered for public assistance under FEMA. This Section 106 consultation was initiated on behalf of the National Historic Preservation Act (NHPA). The NHPA requires all federally funded and/or permitted undertakings to take into consideration their potential to impact historic/cultural resources within the respective jurisdiction of the undertaking.

As per the submitted determination package, the review addressed 15 public schools on St. Thomas and St. John, Virgin Islands. Most were constructed during the modern period, whereas one was rebuilt on an earlier school building site built in the mid-1800s. This school building site is the Leonard Dober Elementary School, which is located within the Charlotte Amalie National Register of Historic Places District.

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VISHPO Consultation with FEMA EHP Determination of Eligibility, Public School Builds St. Thomas & St. John, Virgin Islands USA February 28, 2018 Page 2

The FEMA EHP determination of eligibility for National Register of Historic Places listing for the 15 Public Schools on St. Thomas and St. John found the following;

Not eligible for NRHP due to lack of integrity and significance Addelita Cancryn Junior High School, c. 1960s Charlotte Amalie High School, c. 1955 Gladys A Abraham Elementary School, c. 1965-1983 Ivanna Eudora Kean High School, c. 1971 Jane E. Tuitt Elementary School, constructed 1959 Joseph A Gomez Elementary School, c. 1970 Julius E. Sprauve Elementary School, c. 1957 on St. John

Not eligible for NRHP due to Age Bertha C. Boschulte Middle School, constructed 2002-2003 E. Benjamin Oliver Elementary School, constructed in 1976 Guy H. Benjamin Elementary School, c. 1975 St. John Joseph Sibilly Elementary School, c. 1973 Lockhart Elementary School, c. 2000 Yvonne E. Milliner-Bowsky Elementary School, constructed in 1979. Ulla F. Muller Elementary School, constructed in 2000

The VISHPO does not concur with the determination that all of the above listed properties are not eligible for listing in the National Register of Historic Places, as they presently do not meet the age requirement and/ or presently does not contain the integrity or significance for listing. Specifically, the VISHPO finds that the following schools for age and significance meet the requirements for listing on the National Register of Historic Places;

1. Edith Williams Alternative School, ( one of the early Moravian countryschools)

2. Joseph Sibilly Monroe Annex (was missed on list of schools, countryschool)

3. Guy Benjamin Elementary School ( early country school)4. Ulla F. Muller Elementary School ( early country school and pioneer

model school)5. E. Benjamin Oliver Elementary School (Nationally noted school of

design excellence)

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VISHPO Consultation with FEMA EHP Determination of Eligibility, Public School Builds St. Thomas & St. John, Virgin Islands USA February 28, 2018 Page3

Thank you for consulting with the Virgin Islands State Historic Preservation Office regarding NHPA compliance for this project. Please contact our office, should you have any questions or concerns regarding this Section 106 review.

Sincerely,

Sean L. Krigger, Acting Director And Deputy State Historic Preservation Officer