As the Trump administration nears the two-month mark, the consequences of its sudden and far-reaching policy changes, executive orders, and staffing reductions are being felt across multiple sectors of the economy, and CRM is no exception.
ACRA is actively working with its member firms, allies in the preservation community and federal policymakers to understand the impacts of these actions and respond to them.
Lawmakers Ask ACRA To Alert Them to Stalled and Canceled Contracts
ACRA members shared examples of federal contracts that have been delayed or cancelled with members of Congress last week, joining their preservation allies on Capitol Hill as part of the 2025 Preservation Advocacy Week (more on that below).
Even as they pressed lawmakers to advance legislation promoting historic preservation and cultural heritage, ACRA members reported on their experiences with federal agencies. As a result, multiple lawmakers have asked ACRA and its members to inform them about instances where federal contracts have been cancelled or delayed.
If your firm has had a project cancelled or stalled, please let us know as much information as possible via this form. This information will be used internally by ACRA staff to understand the full scope of cancellations across multiple federal agencies.
Demanding Interior Protect Section 106
As noted last week in the ACRASphere, ACRA has joined with other cultural resource organizations to urge Interior Secretary Doug Burgum to protect and maintain Section 106 regulations at the Department, highlighting the “enormous benefits that Section 106 reviews generate for the nation and its states, tribes, communities, and economy, and how implementation of Section 106 has been accomplished efficiently and effectively for many decades.”
The letter, signed by ACRA, the Society for American Archaeology (SAA), the Society for Historical Archaeology (SHA) and the American Anthropological Association (AAA), comes in response to two Secretarial Orders issued by Burgum that require the Department to review all its policies. In particular, Order No. 3418 Subject: Unleashing American Energy, directs the Department to “review all relevant internal regulations, policies, and guidance to ensure the lawful implementation of Section 106 of the National Historic Preservation Act.”
Tracking The Use of Emergency 106 Procedures
Following the February 19 notice from the Advisory Council on Historic Preservation (ACHP) directing federal agencies to follow emergency procedures for energy projects, ACRA has been in close communication with the Council, its preservation allies, ACRA members and other experts on Section 106 to understand the notice’s implications.
Although the notice and the Executive Order declaring an “energy emergency” do not change the regulations, much less the statute itself, many questions remain about whether the applicability of the 800.12 procedures towards energy projects is appropriate and warranted when the procedures are more commonly used for immediate emergencies such as natural disasters, or where public safety is at stake.
ACRA strongly encourages its members to let ACRA know when and if there are attempts to force through projects without adequate consultation. ACRA will continue working with the ACHP, federal agencies and our preservation allies to continue upholding the core values of safeguarding our past while building for the future.
Responding to NEPA Changes
ACRA also is reviewing an interim final rule issued by the White House Council on Environmental Quality (CEQ) that eliminates CEQ’s regulations implementing the National Environmental Policy Act (NEPA).
Although this rule does not alter the NEPA statute itself, nor does it change individual agencies’ NEPA implementing rules, the move is the most significant change in how the federal government addresses the environmental impacts of its actions in decades.
ACRA is consulting with its allies in the preservation sector to analyze any impacts on CRM and next steps. CEQ is accepting comments on the rule until March 27 at https://www.regulations.gov.
Advocating on the Hill as a Potential Shutdown Looms
The sudden and dramatic policy shifts emanating from the Trump administration continue to be a source of concern, but there’s also a lot at stake for CRM before Congress. ACRA members and their allies in the preservation community took to Capitol Hill last week to press the case to lawmakers that cultural heritage and historic preservation matter as much as ever.
Joining with SHPOs and other national preservation advocates during the 2025 Preservation Advocacy Week, ACRA representatives met with congressional offices to discuss the importance of preserving the Historic Preservation Fund and enhancing the Historic Tax Credit.
Congress’ main task in the coming week is staving off a possible government shutdown, as the stopgap continuing resolution (CR) keeping agencies open expires on March 14. It is increasingly likely that Congress will not be able to pass appropriations bills to fund the government for the remainer of the fiscal year. This means that Congress will need to pass a “full year” CR that maintains funding levels as they were last year.
But it is far from certain Congress will even be able to do that. On the House side, Republican Freedom Caucus members might oppose a CR that doesn’t cut spending; with Democrats likely to all vote no, the House GOP can afford to lose only one Republican lawmaker and still pass the bill. Meanwhile, on the Senate side, Republicans in the majority will need at least seven Democrats to reject a filibuster and move forward – but Democrats, angry about spending cuts and federal workforce dismissals under DOGE, might balk. If one or both chambers can’t pass a CR by Friday, the government could shut down.
If a CR does move forward, that may represent some moderately good news for preservation: allocations from the Historic Preservation Fund would remain at the fiscal 2024 level of $188 million for fiscal 2025, as opposed to the lower amounts that each chamber had proposed.
Meanwhile, ACRA and its advocates are pushing Congress to include in a CR a one-year extension of the HPF’s authorization, which expired last September. That expiration means that monies are not being deposited into the Fund from oil and gas royalties. During Advocacy Week, ACRA members and their allies pressed Congress for a longer-term reauthorization of the Fund, which has garnered bipartisan support in the past. But Congress’ difficulties in competing basic tasks like keeping federal agencies open show the challenge they face thinking long term.
Let Us Know What You Are Hearing and Seeing on March 13
ACRA is holding a Hot Topic session on Thursday, March 13 at 2:00 pm EDT to discuss the latest federal legislative and policy developments. You can register for that session here. Hot Topic sessions are open to all employees of ACRA member firms.