As you know, the National Park Service has invited public comment on troubling proposed regulations that have a direct impact on your work as a CRM professional. Earlier this month we asked you to submit comments on these regulations - if you have not done so yet, we need to you act NOW.
The regulations would give federal agencies power to block National Register listings and eligibility determinations of federally owned properties, and also give large landowners the ability to block historic district and property listings. Not only does this undermine the power of state and tribal historic preservation officers to nominate historic properties on federal land, but the changes also appear to be designed to limit the input of local communities in the National Register listing process while giving more power to large developers.
The deadline to submit comments is this Tuesday, April 30. It is imperative that officials at the Department of the Interior hear from as many of us as possible. ACRA has made it easy for you to do so - by using the template below, you can personalize and send your own comments in just a few minutes.
You are the subject matter expert on issues like this - show that to NPS! Your comments can help improve this proposal and will also be read by courts in future litigation, if necessary. Please join your fellow CRM professionals and act NOW.
TEMPLATE FOR COMMENTS
Your specific expertise matters: please take the time to personalize these comments. The more information you include that is based on your own experiences working in CRM, the more impact your statement will have. Note: if you don't have time to personalize, please remove the words in bold below before submitting!
Submit your comments here.
I write to OPPOSE the proposed changes to the National Register regulations. I am a [insert professional interest in historic preservation—owner of a CRM consulting firm, professional archaeologist, historic architect, etc.] and write to express three major concerns with the proposed changes:
1) The proposed regulations would cut off the ability of SHPOs, THPOs, and local communities and organizations to nominate historic properties located on federal land. The changes would allow only the federal agency to submit nominations of federal properties to the Keeper. This federal overreach is inconsistent with Congress’s intent in the 2016 amendments to solicit more input from SHPOs on federal nominations. [Insert your own examples where properties on federal land were listed through efforts of SHPOs, tribes, local communities or orgs]. These changes would also cause delays in the Section 106 process, because a federal agency could prevent the Keeper from determining the eligibility of federal properties for the National Register. Such delays are contrary to the Administration’s and Congress’s goal of making the permitting review process more efficient.
2) The proposed regulations would allow large landowners to block a nomination of a historic property to the National Register. Currently, a majority of property owners can stop a National Register nomination; each property owner of a historic property gets one vote. The proposed regulations would empower the private owners of a majority of the land area to block a nomination—a change not supported by Congressional authority and clearly designed to give power to large developers to block historic property listings. These proposed regulations are designed to allow mining and energy developers to block National Register listings that encompass large scale landscapes, such as those in Alaska and the western U.S. that are culturally significant to Native Americans. [Insert your own examples of listings that could have been blocked by a majority of landowners]. Giving property owners more votes based on their landholdings is un-American and contrary to the time-tested principle of “one person, one vote.”
3) Finally, I object to the process through which these changes were developed. The National Park Service did not consult with tribes, state historic preservation officers, or other federal agencies, including the Advisory Council on Historic Preservation, to develop this rule. NPS should go back to the drawing board and enlist the expertise of professionals to develop regulations that are consistent with Congress’s intent and longstanding commitment to historic preservation.
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