CRM professionals came to Washington late last month for ACRA’s 2023 Capitol Hill fly-in, the first time ACRA members have met with their elected federal representatives in person since before the pandemic. And their message was clear: investing in preservation is a win-win for everyone.

In their meetings, ACRA members urged their House and Senate representatives to act on these issues:

  • Striking a balance between accelerating infrastructure projects and the need to protect and preserve our historic properties and assets through the Section 106 process.
  • Passing a long-term reauthorization for the Historic Preservation Fund and increasing its authorized level to help states, communities and Tribes continue protecting the places that tell our nation’s story.
  • Providing $225 million for the Historic Preservation Fund for fiscal year 2024 to help states, communities and Tribes facilitate preservation projects and Section 106 reviews.

The Hill meetings came as policymakers in Washington debate ways to reform the permitting review process to enable infrastructure projects to move forward more quickly.

The House GOP’s energy bill, which passed the House in late March, would, among other things, codify into law reforms made to the National Environmental Policy Act (NEPA) by the Trump administration in 2020, which were subsequently rescinded by President Biden when he assumed office; and exempt certain oil, gas and geothermal projects from Sec. 106.

While that bill is not likely to advance in the Democratic-controlled Senate, there is growing appetite for making some changes to permitting processes. Notably, West Virginia Democratic Senator Joe Manchin, who chairs the Senate Energy and Natural Resources Committee, has proposed permitting reform legislation that would set a two-year limit on major federal energy project environmental reviews, although it does not directly impact historic preservation reviews and leaves out many of the more far-reaching NEPA reforms contained in the GOP bill. Last week, the White House indicated that President Biden supports the Manchin bill, setting up a fight between the two parties over how far to go in reforming the federal permitting system.

In their meetings on the Hill, ACRA members stressed that, while the federal permitting process can be made faster and more efficient, weakening preservation laws and exempting entire classes of projects from Section 106 is not the way to do it. Instead, ACRA members made the case that Congress can strengthen the permitting process by:

  • Increasing funding for state and tribal historic preservation offices so they can process reviews efficiently.
  • Encouraging use of programmatic approaches to preservation reviews.
  • Increasing opportunities for public involvement during early stages of project development, avoiding or reducing subsequent controversies and conflicts.
  • Supporting the digitization of historic resources, which improves public access to information and allows for earlier and more efficient review of federal undertakings.

As the debate over permitting reform and preservation continues, ACRA will continue educating federal policymakers about the Section 106 process. To add your voice to the mix and get involved with advocating for the CRM industry, please email us.

ACRA Submits Comments on Proposed Bulletin 38 Revisions

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.