ACRA has submitted comments to the National Park Service in response to their proposed revisions to National Register Bulletin 38: Guidelines for Evaluating and Documenting Traditional Cultural Properties.

First issued in 1990, the TCP Bulletin provides guidance on nominating buildings, structures, objects, sites, and districts believed to have traditional cultural significance for inclusion in the National Register of Historic Places. The Bulletin was last updated in the 1990s, although there was an effort to revise it that was stalled in 2017. NPS has now relaunched that effort, having further refined the 2017 draft last October (you can read the revised draft here.)

In its comments, ACRA noted that many CRM firms are actively involved with Tribal programs, consultation, and the documentation of Traditional Cultural Places (TCPs) and other ethnographic/ethnohistoric places. ACRA told NPS that these firms “need clear direction and precise language and definitions from NPS on the protocols and procedures for documentation and evaluation of TCPs, particularly with respect to who is best qualified to judge the eligibility of a TCP,  and around the consultation process with traditional communities.”

ACRA indicated it supported some of the revisions that NPS has proposed, such as the draft’s use of the term “traditional cultural places” over “properties,” to avoid the implications inherent in the word. ACRA also asked NPS to alter or clarify certain proposed changes, such as language that suggests that TCPs may be documented over the objection of a community; as ACRA points out, “this fails to reflect respect of community perspective as well as proper National Register of Historic Places (NR) procedures.”

You can read ACRA’s comments here.