This post is authored by Charles M. Niquette, founding member of ACRA and Chairman of the Board of Cultural Resource Analysts, Inc.

Many in the historic preservation community are understandably alarmed by the current effort to eviscerate the regulations implementing Section 106 of the National Historic Preservation Act. We should be alarmed. But we should not be paralyzed. This is not our first rodeo. We have faced serious threats to the federal historic preservation program before. We survived them because the preservation community became organized, coordinated, and politically engaged. That history offers an important lesson for us today: when preservationists act separately, we are relatively easy to ignore, but when we act together, we represent a remarkably broad national constituency.

The first major attack came in the early 1980s under the Reagan Administration. President Reagan championed “New Federalism,” an effort to reduce the size and reach of the federal government, return greater authority to the states, deregulate the private sector, and remove what the administration regarded as unnecessary federal impediments to economic development. Historic preservation was caught squarely in that effort. The administration repeatedly proposed drastic reductions—and at times essentially zero federal funding—for major components of the federal historic preservation program, including grants to State Historic Preservation Offices and support for the National Trust for Historic Preservation. The larger message was unmistakable, Washington should have a smaller role, federal regulatory requirements should be reduced, and state and private interests should assume greater responsibility. Federal review was portrayed as bureaucracy. Consultation was process. Regulation was an impediment to development. The solution offered was to reduce the federal role. We had heard it before then, and we are hearing it again now.

The preservation community responded by organizing. There was no email, social media, or internet campaign. We wrote actual letters—thousands of them—to members of Congress. Preservation organizations, archaeologists, architectural historians, SHPOs, local preservationists, and concerned citizens made themselves heard. I remember a congressional staffer describing the response this way, “The historic preservation community is very broad but not necessarily deep.” I have remembered that observation for more than forty years. It was both a compliment and a warning. We represented an extraordinarily broad constituency, but breadth matters politically only when people are willing to act. They acted then, and we prevailed.

We faced another major challenge in 1995. That July, amid broader efforts in the House of Representatives to reduce spending on federal environmental and cultural programs, funding for the Advisory Council on Historic Preservation was placed in jeopardy. ACRA sounded the alarm. Loretta Neumann, our lobbyist at the time and owner of CEHP, Inc., and Nellie Longsworth of Preservation Action helped organize the response. We reached out to the Society for American Archaeology (SAA), the National Trust for Historic Preservation, the Society for Historical Archaeology (SHA), and other preservation organizations. Organizations with different memberships, missions, and priorities suddenly had a common cause, and they responded.

Members contacted Congress. Organizations mobilized their constituencies. Preservation advocates made the case that the National Historic Preservation Act and the federal review process enjoyed support extending far beyond a small group of archaeologists and preservation professionals. On July 14, 1995, the House restored funding for the Advisory Council. We should remember that episode today. Congress discovered that historic preservation had a constituency—and that constituency was capable of mobilizing.

About a decade later, we faced another challenge involving something even more fundamental to Section 106, identifying which historic properties the process should protect. During congressional consideration of possible amendments to the National Historic Preservation Act, proposals emerged that would have weakened the protection afforded properties that were eligible for, but not yet formally listed in, the National Register of Historic Places. That distinction is enormously important.

Thousands of historically significant archaeological sites, buildings, landscapes, traditional cultural places, battlefields, cemeteries, and other resources have never been formally listed in the National Register. Section 106 works precisely because federal agencies must consider properties that meet the National Register criteria whether or not someone previously completed the paperwork necessary to nominate them. Eliminating protection for eligible-but not listed properties would have fundamentally changed the law.

One of the most compelling arguments against that proposal came from Joel Klein, writing on behalf of the Coalition of 9/11 Families. He pointed to the places associated with the September 11 attacks and the absurd consequences of a system that protected historically significant places only after they had been formally listed. His argument was poignantly simple, historic significance does not suddenly appear when someone completes a National Register nomination form.

The proposal ultimately went nowhere, the preservation community survived. And Here We Are Again. Now, in 2026, we face another attempt to fundamentally reshape Section 106. The circumstances are different. The politics are different. The proposed regulatory changes are different. But the lesson from our history is remarkably consistent.

We cannot fight this organization by organization, profession by profession, or state by state. Archaeologists cannot do it alone. Architectural historians cannot do it alone. State Historic Preservation Officers (SHPOs) cannot do it alone. Tribes should not be expected to carry the fight alone. Neither can ACRA, SAA, SHA, the National Trust, Preservation Action, state and local preservation organizations, or any other single group. But collectively we represent something much larger, broad and deep!

We represent private businesses and their employees. We represent universities and museums. We represent state, tribal, and local governments. We represent historic neighborhoods, rural communities, descendant communities, preservation commissions, historical societies, Main Street organizations, battlefield groups, Tribal HPOs , developers, engineers, planners, and citizens who simply care about the places that tell the beloved stories of their communities. And that is before we even begin talking to the people who should be our natural allies: environmental organizations, local governments, Indian Tribes, veterans’ organizations, Civil War and battlefield preservation groups, conservation organizations, outdoor recreation groups, neighborhood associations, genealogical societies, and responsible developers who understand the value of identifying problems before construction begins. Our shared mission is our strength, our unity is the lessons learned.

The preservation community may still be extraordinarily broad. This time, we need to make it deep as well. We Need a Coordinated Strategy. We should not simply react to whatever comes out of Washington. We need our own strategy.

We need to identify the provisions that genuinely threaten the purposes of Section 106 and explain—in plain English—what their consequences will be. We need consistent messages that every preservation organization can carry to Congress, governors, mayors, tribal governments, federal agencies, project proponents, the media, and the public.

We need examples showing where Section 106 has worked—not abstract discussions about regulatory procedure, but highways that were built, factories that opened, energy projects that proceeded, communities that were heard, archaeological sites that were investigated, historic places that were preserved, and expensive conflicts that were avoided because somebody asked the right questions early enough.

And we should be willing to acknowledge where the existing process does not work well. There is unnecessary paperwork. There are reviews that take too long. There are federal agencies that fail to take responsibility for their own Section 106 obligations. There are archaeological investigations that collect information nobody needs to make a federal decision. There are opportunities to use technology, predictive modeling, electronic consultation, earlier better project planning, programmatic approaches to compliance and enforceable review schedules to make Section 106 faster and more efficient and effective.

We should be leading that discussion rather than allowing others to define “streamlining” as eliminating consultation, identification, or public participation. Our position should not be that the regulations are perfect. We know where the problems are. We have spent decades working under these regulations. Let us help fix them without destroying what works. That is a much stronger position than simply defending the status quo.

We have done this before. In the 1980s, we organized. In 1995, we organized. When fundamental protections for places eligible for listing in the National Register of Historic Places were threatened, we organized again. Each time, people who might otherwise have pursued their own institutional interests recognized that they had something larger in common. We need that same recognition now.

ACRA has been continually working with other national organizations on a unified strategy since the announcement of the vote by the ACHP and will continue to do so. You will notice that many of the resources and communications you will find on the Section 106 Action Center reflect this strategy, sharing similarities to resources from our preservation partners. The preservation community does not need dozens of independent responses to the same threat, but instead to work towards a unified goal. The messaging for each sector of that community may differ slightly as we work towards that goal, but the important part is that we work together to get there.

We need a coalition. We need a strategy. And we need to start acting like one community again.

This is not our first rodeo. History suggests that when we ride together, Washington notices.

Charles M. “Chuck” Niquette earned his M.A. from the University of Arkansas and began his professional career in federal historic preservation, working with Interagency Archaeological Services of the National Park Service and later with the Advisory Council on Historic Preservation. Following his federal service, he worked briefly for Environmental Consultants, Inc. before founding Cultural Resource Analysts, Inc. (CRA) in 1983. Under Niquette’s leadership, CRA grew from a one-person operation into one of the nation’s larger cultural resource management firms, with offices in eight states and approximately 100 employees. Over more than four decades, he has been actively involved in the growth and professionalization of the cultural resource management industry. Niquette was also a founding member of the American Cultural Resources Association (ACRA) and served as its first president.