MARCH 22, 2019

Proposed Rule Change on National Historic Preservation Act Regulations Impacts National Register Nominations

The National Park Service is seeking public comment on proposed revisions to National Historic Preservation Act (NHPA) regulations that would have a substantial impact on how properties are listed on the National Register of Historic Places. The period for public comments are open for 60 days, closing April 30, 2019According to the National Park Service:

"The intent of the proposed rule is to bring regulations current with amendments to the National Historic Preservation Act (NHPA), signed into law in 2016, and to emphasize the rights of private property owners with the overall intent to streamline processes for the nomination of properties in the National Register by federal agencies."

After reviewing the proposed rule changes, Preservation Action is extremely concerned by the impact these changes would have on National Register nominations. While the stated intent is to bring regulations current with amendments to the NHPA from the National Park Service Centennial Act, signed into law in 2016, several of the proposed rule changes clearly go far beyond the intention of the Centennial Act amendments and the NHPA. 

The proposed rule virtually gives federal agencies unilateral control in determining if a historic resource on federal land can be listed on the National Register of Historic Places. While not explicitly stating that a federal agency can block a National Register nomination, it allows a federal agency to leave a nomination in what amounts to a regulatory purgatory, effectively killing a nomination.

Additionally, the proposed rule, changes the requirement that a property shall not be listed on the National Register over the objections of a "majority of property owners" to include both a "majority of property owners" and the "owners of a majority of the land area of the property". Nowhere in the National Historic Preservation Act does it refer to land owners or land area in regards to determination, nor does the Secretary of Interior have authority to make such a change. Furthermore, placing the responsibility on State Historic Preservation Officers to make these determinations could be so burdensome that the listing of historic districts becomes virtually impossible. 

The proposed rule undermines the intention of the NHPA and could have a devastating impact on national register nominations.  It is critically important that everyone submits comments to the proposed rule at the link below. Comments are due by April 30th.

Historic Preservation Caucus Co-Chairs Lead Dear Colleague Letter in Support of the Historic Preservation Fund

Congressman Mike Turner (R-OH) speaking during National Historic Preservation Advocacy Week 2019
As Congress begins work on the FY20 budget and appropriations, the bipartisan co-chairs of the Historic Preservation Caucus, Rep. Earl Blumenauer (D-OR) and Rep. Mike Turner (R-OH), are leading the FY20 Historic Preservation Fund Dear Colleague Letter. The letter calls for $141 million in funding for the HPF, including increases for State and Tribal Historic Preservation Offices, and increases to critically important competitive grant programs.The letter will be submitted to the Interior Appropriations Subcommittee

This marks a strong commitment to the HPF and we can't thank Representatives Blumenauer and Turner enough for their continued support and leadership on the HPF. Urge your Representative to sign-on to the FY20 Historic Preservation Fund Dear Colleague Letter. Members can sign-on by contacting Jon Bosworth in Rep. Blumenauer's office or Jeffrey Wilson in Rep. Turner's office. The deadline for signatures is Wednesday, March 27th.

We are off to a strong start with 54 signers, but are still short of total number of signatures from last year. Do you already have a contact in your Representative's office? If not, call your Representative's office and ask to speak to the staff person in charge of historic preservation issues. Reach out and let them know who you are and why historic preservation matters to you. U rge them to sign-on to the Historic Preservation Fund Dear Colleague Letter being circulated by Rep. Turner and Rep. Blumenauer. 

Stay tuned for details regarding the Senate HPF dear colleague letter in the near future. We are working with our partners and Senate staff to finalize the Senate letter.
President Trump's FY20 Budget Request Proposes Dramatic Cuts to Historic Preservation

President Trump released his FY20 Department of Interior budget request this week, once again the request calls for dramatic cuts to the Historic Preservation Fund (HPF) and other preservation priorities.  The request eliminates preservation grant programs and only includes $32.7 million for the HPF, $69.96 million below FY19 levels. The full breakdown is below.

State Historic Preservation Offices: $26.9M, $22.775M below FY19 levels 
Tribal Historic Preservation Offices: $5.7M, $6.035M below FY19 levels

The request eliminates funding for the African American Civil Rights grant program, underrepresented communities grant program, Save America's Treasures, HBCU preservation grants, and historic revitalization significance grants. The request also eliminates funding for the Heritage Partnership Program which supports National Heritage Areas, and the National Endowment for the Arts and Humanities.

While the President's budget request is concerning, Congress rejected similar cuts proposed in previous years. Congress continues to show strong support for Historic Preservation Fund and other preservation priorities, including providing a record level of funding for the HPF in FY19. Lawmakers in the House and Senate are currently drafting an overall budget which will be the basis for appropriations.  

You can help reject these harmful cuts by encouraging your Representative to sign-on to the FY20 Historic Preservation Fund Dear Colleague Letter. Reach out to your representative today. The deadline for signatures is March 27th.
Thank You for Another Successful National Historic Preservation Advocacy Week!

Congressman Betty McCollum (D-MN) alongside Preservation Action President, Russ Carnahan and MN Deputy SHPO, Amy Spong at the Champions of Historic Preservation reception during Advocacy Week.
Preservation Action along with our partners at the National Conference of State Historic Preservation Officers just concluded another great National Historic Preservation Advocacy Week in Washington, DC last week. We were joined by nearly 200 participants, representing 40 states, Puerto Rico and the District of Columbia. Thank you to everyone that helped make Advocacy Week 2019 a huge success. 

The gathered group of preservation advocates were fortunate to hear from national preservation leaders and policy experts on the current legislative landscape and insight on conducting successful congressional visits. We were also honored to be joined by Rep. Mike Turner (R-OH), Rep. Brian Higgins (D-NY), and Rep. Raul Grijalva (D-AZ), who shared their unique perspectives on why historic preservation is important and how we could all be better preservation advocates.

Tersh Boasberg and Preservation Action board member, Lisa Craig, alongside Nellie Longsworth's family at the Champions of Historic Preservation reception during Advocacy Week 2019.
The next day advocates from across the country took to the Hill where we conducted nearly 200 congressional visits. In the evening, Preservation Action hosted the Champions of Historic Preservation Congressional Reception. We recognized Rep. Betty McCollum (D-MN) and Rep. Darin LaHood (R-IL) for their continued, steadfast support of historic preservation. We were also very pleased to honor Preservation Action founding member, Tersh Boasberg, with the inaugural Nellie Longsworth Award for Outstanding Achievement in Citizen Advocacy for Historic Preservation, named after historic preservation advocacy pioneer and Preservation Action's first Executive Director, Nellie Longsworth

Hill Report Forms/Follow-Up

Please submit your Advocacy Week Hill Report Forms. Knowing how your meetings went is critical for our continued advocacy. You can complete your report form online or return completed forms to

As preservationists return to the their home states as Hill veterans, remember to follow-up from your congressional visits. Perhaps you can send a personalized thank you note and invite members and staff to tour a historic tax credit project in-district.

Preservation Action
2020 Pennsylvania Ave NW #313
Washington, DC 20006
p. 202-463-0970

Preservation Action is the only national  non-profit dedicated exclusively to lobbying for the best preservation policies at the federal level. We seek to make historic preservation a national priority by advocating to all branches of government through a grassroots constituency empowered with information and training.