Beyond ACHP: The Preservation Movement's Moment of Reimagination
While the Advisory Council on Historic Preservation is the primary convening agency across the federal government, they are not the only institution with reimagination work to do, especially as the National Historic Preservation Act (NHPA) of 1966 turns 60 years old.
Universities and their professional accreditation boards, local and state offices, and allied federal agencies such as the Department of Interior and National Park Service have been revisiting fundamental ideas about what preservation means in a diasporic and diverse world.
This essay seeks to summarize the longstanding but clarified critiques of historic preservation that have reached the federal and national levels. It draws on recent works pointing out the structurally defined limitations of 20th-century foundational practices in need of revision and recoloring with new layers of visions appropriate for the multiple constituencies of the early 21st century.
Rethinking Federal Designation Practices: Perspectives from State and tribal Preservationists
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Rethinking Federal Designation Practices: Perspectives from State and tribal Preservationists 〰️
In 2021, The National Conference of State Historic Preservation Officers (NCSHPO, pronounced 'nick-ship-oh") convened a Historic Designation Advisory Committee (NHDAC) with officers representing both states and tribes. They set out to "examine the intent, history, and implementation of the NHRP with an eye towards fostering greater access and inclusion" (2023, pg. 1). Between June and October 2021, the Survey and Data Subcommittee produced a 50+page Historiography consisting of over 140 academic, professional, and popular articles focusing on historic preservation and the National Register, published from 1965 to now. In April 2023, they released the full report and an executive summary.
Their extensive methodology with multiple methods of investigation of both contemporary professionals and of historical literature results in a few key findings that are clear calls to inclusive action.
Maintaining Relevance and Direct Utility for Overlooked Cultural Traditions
In general, the NRHP remains relevant and useful as a sorting and planning tool for federal and state agencies, encouraging rehabilitation projects, and improving preservation outcomes. They do not question that. Overall, NCSHPO begins by acknowledging how popular opinions diverge from the actual function of the National Historic Register Program (NHRP), "one of the most widely known yet misunderstood programs in the United States." While most people believe that the nearly 100,000 listings of cultural heritage sites and objects is "generally simple - a national list that commemorates historic places widely assumed to be protected from further destruction", the NRHP goes beyond recognition to act "as a planning tool that triggers a variety of different federal regulatory processes, for which 'protection' may be encouraged, but not guaranteed." This expansion of audiences yet narrowing of authority creates two sources of challenges to what they conclude is a "predominantly honorific" designation.
However, its utility is limited in ways that are inequitable for those who do not meet their narrow pre-qualifications for support.
NHRP suffers from false perceptions. "The public does not fully understand the program, its rules or its limitations, the expectations regarding documentation can be onerous and expensive, and listing does not in and of itself offer protection," the report declares.
NHRP may also be irrelevant for places without some physical material. "The NRHP does not optimally address places of cultural memory, non-traditional physical integrity, or places where there is little physical footprint"
NHRP may also appear to be an elitist tool that favors the famous, rather than a tool to discover treasures without a known brand. (pg. 7): "The National Register is not a good tool for preserving sites associated with the everyday life of people; too much emphasis is placed on aesthetics and historic integrity."
They argue that the local "landmarking" process is likely better for the protection of sensitive cultural landscapes like a cemetery, rather than a national honorific of being registered but without guarantees of being protected from demolition. "A local landmarking process, which takes less time and usually less effort, will serve the purpose better." (pg. 8)
States have made up for this federal gap with local programs that honor intangible heritage. States have developed alternative and additional designation programs that address cemeteries, heritage traditions, and other aspects of culture that don’t fit neatly in the rubric of the NRHP.
Questioning Physical "Integrity" as an Elitist Standard
Notions of "integrity" are not clear or fair to communities explicitly dealing with erasure. "It also can be seen as a barrier to communities and individuals where marginalization, lack of investment or erasure have made integrity, in a physical sense, a serious challenge."
Integrity is also seen as a colonial/Western concept. "Integrity is also not part of the tribal worldview, so focusing on the physical aspects of integrity over feeling and association frankly can favor the built environment over cultural landscapes." They note that the National Park Service has tried to address this with new tools like "Multiple Property Documentation" forms but these are still "poorly understood and underused."
In particular, on the notion of designating sites without physical integrity, they see a lack of deep empathy and even open discussion of ways to prioritize the sites of erasure (pg.6).
"A variety of historical, environmental, economic or social changes have been caused by a number of forces including development, natural disasters, migration and settlement, abandonment, assimilation, slavery, racial segregation, discrimination, economic disruptions, urban renewal, transportation corridor expansions, disinvestment, environmental degradation or a combination thereof. These forces have often impacted, damaged, destroyed, hid, or erased historical places."
These professional struggles over domains of integrity, documentation, and "Traditional Cultural Places" have caused some fundamental and existential questions over the core programs in preservation. On page 18, they write: "There also was a fair amount of debate on the overall goal of the National Register itself – is it to tell the full story, is it to be a list of sites worthy of preservation, and what to do if there is little or nothing physical left to preserve….it could still be that for some cases the best solution for some types of resources would be a new and/or additional program that provides recognition but may not include all the physical characteristics and corresponding treatment standards that accompany the existing National Register program."
Clarifying Top-Down v.s. Bottom-Up Authority over Cultural Heritage
Different administrative cultures are a source of tension. Specifically, they write, "Tension exists between the grassroots “DNA” of the historic preservation movement and the formalized academic “professionalized” approach into which it has evolved." This is especially true when a site has some federal involvement in a local cultural identity.
Tensions exist over the outdated nature of the designation guidance in NPS. "Current NPS guidance further hampers the effort, as relevant bulletins are outdated and insufficient to address a broader perspective in the designation process." For example, Bulletin 25 defines what a "Traditional Cultural Place" or TCP is, but in ways that may not invite the characteristics that local, indigenous or tribal communities consider.
Funding is also a major source of tension for SHPOs trying to expand and diversify their designated sites. "Surveys that do not result in an NRHP nomination as the end product are not eligible for reimbursement by HPF. This reality handicaps local governments from taking the first step in identifying their historic resources."
Ending Inaccessibility for Applicants
NHRP is seen as overly complicated for a lay citizen to contribute or nominate. "Over time the process for listing has become so byzantine and cumbersome that it has inadvertently created significant barriers for listing properties."
The result is a de facto “pay to play” model that promotes an inequitable pipeline of nominations that may not be reflective of all communities’ preservation priorities.
NDAC report calls attention toward the "Excessive documentation standards for nominations, particularly those proposing Criteria A and B (non-architectural) significance" as a source of inaccessibility and costly applications.
Locally, "Panelists representing tribes, in particular, noted that traditional knowledge and oral history were often viewed by state review boards and National Register reviewers as less credible sources of information than archaeological data and written records.
Even when locals attempt to carry forward their own applications, it does not guarantee acceptance. "Nominations prepared under the guidance of SHPOs and approved by state boards are routinely found to be deficient by reviewers at the federal level."
While a new report, the NCSHPO authors acknowledged the longstanding history upon which their recommendations are derived. The Survey committee also had three major takeaways from the literature review. "Despite its limitations, this Historiography suggested the following three major takeaways to the NHDAC Scholarship/Data Committee:
The desire to increase equity, inclusion, and representation in the National Register is not a new call to action.
Localized preservation advocacy efforts are a critical component for National Register nominations, and the majority of nominations made for local level of significance reflects this grassroots nature of historic preservation.
If American History is complicated, how do we make national historic designation programs like the National Register of Historic Places able to accommodate this complexity.