2015
An independent federal agency, the Advisory Council on Historic Preservation (ACHP) promotes 

the preservation, enhancement, and sustainable use of our nation’s diverse historic resources and 

advises the President and Congress on national historic preservation policy. It also provides a forum 

for influencing federal activities, programs, and policies that affect historic properties. In addition, 

the ACHP has a key role in carrying out the Preserve America program.

Milford Wayne Donaldson, FAIA, of Sacramento, California, is chairman of the 23-member 

ACHP, which is served by a professional staff in Washington, D. C. For more information about 

the ACHP, contact:

Advisory Council on Historic Preservation

401 F Street, NW

Suite 308

Washington, D. C. 20001-2637

Phone: 202-517-0200

Web sites: www.achp.gov and www.preserveamerica.gov

Front cover photography (left to right): Black Rock Lock and Canal, NY (USACE); Cathlapotle Pole House 

constructed in Ridgefield National Wildlife Refuge, WA (USFWS); and Space Shuttle in transit (NASA)

Back cover photography (left to right): RV Polaris, CA (USGS); students volunteer in an archaeological dig 

in a national park in the National Capital Region (NPS); the restored main stair balustrade in the Treasury 

Building, DC (TREAS); and the Westport Post Office, CT (Evan Kalish)

Preserving America’s Heritage
TABLE OF CONTENTS

ACKNOWLEDGEMENTS.............................................................................................................................................. 5

ACRONYMS AND ABBREVIATIONS........................................................................................................................ 6

CHAIRMAN’S MESSAGE ............................................................................................................................................... 7

SECRETARY OF THE INTERIOR’S MESSAGE....................................................................................................... 8

EXECUTIVE SUMMARY ................................................................................................................................................ 9

CHAPTER 1: INTRODUCTION AND BACKGROUND.................................................................................... 12

Executive Order No. 13287 – Preserve America (2003)........................................................................................................13

Preserve America Community and Stewards Programs.........................................................................................................14

Previous Section 3 Reporting......................................................................................................................................................15

Framework for 2015 Report to the President...........................................................................................................................18

CHAPTER 2: CURRENT STATE OF REAL PROPERTY MANAGEMENT................................................. 19

Continuing Policies and Initiatives.............................................................................................................................................19

New Policies and Initiatives.........................................................................................................................................................25

Building a More Inclusive Preservation Program.....................................................................................................................28

50th Anniversary of the National Historic Preservation Act..................................................................................................29

Correlation to Agencies’ Section 3 Progress Reports ..............................................................................................................29

CHAPTER 3: CURRENT STATE OF FEDERAL STEWARDSHIP.................................................................. 30

Inventories of Historic Properties...............................................................................................................................................31

Funding ...........................................................................................................................................................................................31

Federal Real Property Profile and Other Databases................................................................................................................31

Notable Inventory Studies...........................................................................................................................................................34

Section 110 and Section 106.......................................................................................................................................................35

Stewardship and Agency Planning .............................................................................................................................................35

Agency Policies and Procedures..................................................................................................................................................36

Consolidation .................................................................................................................................................................................37

Master Planning.............................................................................................................................................................................37

Leasing and Other Cost Sharing Approaches ..........................................................................................................................40

Demolition and Disposal .............................................................................................................................................................42

Climate Change.............................................................................................................................................................................44

Managing Assets............................................................................................................................................................................45

Highly Technical Historic Properties........................................................................................................................................45

Rehabilitation for Improved Sustainability...............................................................................................................................47

FRONT MATTER | 3
Other Historic Property Management......................................................................................................................................48

Contributing to the Economy......................................................................................................................................................51

Building Partnerships....................................................................................................................................................................53

Summary.........................................................................................................................................................................................59

CHAPTER 4: FINDINGS AND RECOMMENDATIONS................................................................................... 60

FINDING NO. 1: Federal Property Consolidation and Realignment...............................................................................61

FINDING NO. 2: Energy Efficiency and Sustainability ......................................................................................................64

FINDING NO. 3: Climate Change and Adaption................................................................................................................65

FINDING NO. 4: Federal Preservation Programs in the 21st Century .............................................................................66

Summary.........................................................................................................................................................................................68

CHAPTER 5: TOWARD A COMMON GOAL ........................................................................................................ 69

CASE STUDIES

Retirement of the Space Shuttle Program as a Gift to the American People......................................................................17

Historic Post Office Disposals....................................................................................................................................................21

Inventory Data Management.......................................................................................................................................................33

Facility Planning For Preservation Outcomes..........................................................................................................................38

Historic Federal Buildings Go Platinum and Net-Zero ........................................................................................................49

Measuring the Economic Effects of Federal Historic Preservation ......................................................................................54

Preservation Through Disposal and Partnership.....................................................................................................................57

Protecting Historic Properties From the Effects of Climate Change...................................................................................71

APPENDIX A: EXECUTIVE ORDER 13287, PRESERVE AMERICA.............................................................. 74

APPENDIX B: ADVISORY COUNCIL ON HISTORIC PRESERVATION MEMBERSHIP..................... 78

APPENDIX C: AGENCY SECTION 3 REPORTS SUBMITTED, 2004–2014.............................................79

APPENDIX D: ADVISORY GUIDELINES IMPLEMENTING SECTION 3: 

REPORTING PROGRESS ON THE IDENTIFICATION, PROTECTION, AND USE OF 

FEDERAL HISTORIC PROPERTIES......................................................................................................................... 81

APPENDIX E: FEDERAL REAL PROPERTY REPORTING.............................................................................. 83

4 | FRONT MATTER
ACKNOWLEDGEMENTS

The Advisory Council on Historic Preservation appreciates and thanks the following 

individuals and organizations for their time and contribution in assisting the agency to 

implement the provisions of Section 3 of Executive Order No. 13287:

FEDERAL AGENCY PROGRAMS COMMITTEE

Architect of the Capitol, Chair

National Trust for Historic Preservation, Vice Chair

Teresa Leger de Fernandez

Dorothy Lippert 

Leonard Forsman

Secretary of Agriculture

Secretary of Defense

Secretary of Homeland Security

Secretary of Housing and Urban Development

Secretary of the Interior

Secretary of Transportation

Secretary of Veterans Affairs

Administrator, General Services Administration

President, National Conference of State Historic Preservation Officers

General Chairman, National Association of Tribal Historic Preservation Officers, Observer

Chairman, Council on Environmental Quality, Observer

ADVISORY COUNCIL ON HISTORIC PRESERVATION

John M. Fowler, Executive Director

Reid J. Nelson, Director, Office of Federal Agency Programs

Caroline D. Hall, Assistant Director, Office of Federal Agency Programs (co-author)

Katry Harris, Program Analyst (co-author)

Susan Glimcher, Director, Office of Communications, Education, and Outreach

Ronald D. Anzalone, Director, Office of Preservation Initiatives

Druscilla J. Null, Senior Program Analyst

Shayla Shrieves, Senior Writer-Editor

DEPARTMENT OF THE INTERIOR

Stephanie Toothman, Ph.D., Associate Director, Cultural Resources, Partnerships, and 

Science, National Park Service

FRONT MATTER | 5
ACRONYMS AND ABBREVIATIONS

ACHP Advisory Council on Historic 

Preservation

AFRH Armed Forces Retirement Home

ARRA American Recovery and Reinvestment 

Act

BIA Bureau of Indian Affairs

BLM Bureau of Land Management

BOP Federal Bureau of Prisons

BOR Bureau of Reclamation

BRAC Base Realignment and Closure 

CBP U.S. Customs and Border Protection

CDC U.S. Centers for Disease Control and 

Prevention

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

DHS Department of Homeland Security

DOC Department of Commerce

DOD Department of Defense

DOI Department of the Interior

DOS Department of State

DOT Department of Transportation

EO Executive Order

EUL Enhanced Use Lease

FAA Federal Aviation Administration

FDA Food and Drug Administration

FEMA Federal Emergency Management 

Agency

FHWA Federal Highway Administration

FPO Federal Preservation Officer

FRPC Federal Real Property Council

FRPP Federal Real Property Profile

FS U.S. Forest Service

FWS U.S. Fish and Wildlife Service

GAO Government Accountability Office

GIS Geographic Information System

GSA General Services Administration

HHS Department of Health and Human 

Services

IHS Indian Health Service

LEED Leadership in Energy and 

Environmental Design

NASA National Aeronautics and Space 

Administration

NEPA National Environmental Policy Act

NHL National Historic Landmark

NHPA National Historic Preservation Act

NIH National Institutes of Health

NOAA National Oceanic and Atmospheric 

Administration

NPS National Park Service

NRHP National Register of Historic Places

OMB Office of Management and Budget

RPAC Real Property Advisory Committee

SHPO State Historic Preservation Officer

SPO Senior Policy Official

Stat. U.S. Statues at Large

TVA Tennessee Valley Authority

U.S. United States of America

U.S.C. Code of Laws of the United States of 

America

USACE U.S. Army Corps of Engineers

USCG U.S. Coast Guard

USGBC U.S. Green Building Council

USGS U.S. Geological Survey

USPS U.S. Postal Service

VA Department of Veterans Affairs

6 | FRONT MATTER
MILFORD WAYNE 

DONALDSON, FAIA

Chairman, Advisory Council 

on Historic Preservation

February 17, 2015

CHAIRMAN’S MESSAGE

In accordance with Executive Order 13287 “Preserve America,” the Advisory Council on 

Historic Preservation (ACHP) is pleased to present its fourth triennial report on how 

well federal agencies manage the historic properties entrusted to their care on behalf of 

the American people. Federal agencies provided progress reports to the ACHP and the 

Secretary of the Interior in 2014. Based on these submissions and our interactions with 

federal agencies, the ACHP has developed findings and associated recommendations to 

advance the goals of the Executive Order and the National Historic Preservation Act.

The Preserve America Executive Order requires agencies to advance the protection, 

enhancement, and contemporary use of historic properties owned by the federal 

government. As agencies continue to work smarter and reduce the federal footprint 

to control costs, they have also found opportunities to optimize the use of historic 

properties to meet mission requirements, increase energy efficiency and sustainability, 

and promote economic development. 

Federal agencies have used various tools to make productive use of historic properties, 

including outleasing and other cost sharing partnerships. Through outleases and 

enhanced use leases, federal agencies may ensure the long-term preservation of historic 

properties supported by non-federal investment. These approaches present an alternative 

to demolition and are often effective alternatives for the reuse of highly technical or 

scientific historic properties.

In their 2014 progress reports, agencies reported on the successful “green design” adaptive 

reuse and rehabilitation of federal historic buildings and structures. Creative design 

teams have proven that historic buildings and structures can become high-energy 

performers with investments in new technologies, making investment in rehabilitated 

historic buildings and structures federal dollars well-spent.

The ACHP is committed to actions that support the Administration goals of cost 

efficient, effective, sustainable, and resilient federal real property management. We are 

also committed to building a more inclusive preservation program, and ensuring that the 

diverse cultures of our nation, as well as our nation’s young people, are well represented 

in historic preservation. We continue to encourage federal leadership and interest in the 

stewardship of historic properties in federal ownership and appreciate the attention given 

to this important report. 

FRONT MATTER | 7
SALLY JEWELL

Secretary, Department of 

the Interior

February 17, 2015

SECRE TARY OF THE I NTERIOR’ S 

MESSAGE

Since President Lyndon Johnson signed the National Historic Preservation Act in 

1966, stewardship of historic places has been part of the mission of every Federal agency. 

Across the country, Federal employees are working every day to meet the responsibility to 

be good managers of the many significant historical sites. Historic preservation programs, 

such as those managed by the Federal preservation offices within the Department of 

the Interior, ensure that places with historic and cultural significance are appropriately 

identified, evaluated, and protected. 

The Department of the Interior sets the standards by which the qualities of preservation 

are measured and evaluated by Federal, state, tribal, and local communities and citizens. 

In concert with the National Register of Historic Places criteria, the Secretary of the 

Interior’s Standards guide the practice of American historic preservation. More than 

90,000 historic places representing approximately 1.6 million properties are listed on the 

National Register. 

Federal historic preservation programs make civic, economic, and environmental sense. 

In addition to teaching our citizens about our great national journey, preservation 

generates many economic benefits, stimulating the creation of jobs and investments in 

local economies. 

Long recognized for its contribution to environmental sustainability, historic preservation 

is now confronting the impact of climate change on cultural resources. This new 

challenge has prompted a renewed effort to meet our responsibilities to identify, evaluate, 

document, and nominate properties to the National Register of Historic Places. 

The Federal agency reports show steady progress at identifying historic places as the first 

step in ensuring that accurate data about significant places are used in making decisions. 

However, improved accessibility of this information for other Federal, state, tribal, and 

local preservation offices is needed. At the Department of the Interior, we continue to 

work to make inventory systems compatible across the bureaus. 

In the coming decades, our preservation efforts must become more relevant and inclusive 

of the many histories that make up the panorama of the American story. Since 2000, 

more than a dozen theme studies exploring the diversity of the American experience have 

been completed. Following the recently released report on American Latino heritage, we 

are now undertaking historical studies of women; Asian Americans and Pacific Islanders; 

and lesbian, gay, bisexual, and transgender Americans. 

In 2016, Federal historic preservation programs will commemorate the 100th 

anniversary of the establishment of the National Park Service and the 50th anniversary 

of the passage of the National Historic Preservation Act. Both of these events offer 

opportunities to recognize how important the stewardship of our historic places and 

shared heritage is to the foundation of the American character and to recommit ourselves 

to these efforts. 

8 | FRONT MATTER
EXECUTIVE SUMMARY

This is the fourth triennial report to the President, required under Executive Order (EO) 

No. 13287, “Preserve America,” addressing the state of the federal government’s historic 

properties and their contribution to local economic development. EO 13287 reinforces 

the role of federal agencies as stewards of historic properties under their ownership 

and underscores the importance of federal agency efforts to inventory, protect, and use 

these properties. The EO emphasizes that historic properties are valuable assets to 

support agency missions, and federal investment in them may stimulate local economic 

development.

Information in this report is derived primarily from the federal agency progress 

reports submitted to the Advisory Council on Historic Preservation (ACHP) and the 

Secretary of the Interior in September 2014. Agency reports focused on progress made 

in identifying, protecting, and using historic properties in federal ownership. Federal 

agencies continue to provide creative examples of historic properties adaptively reused 

and rehabilitated to be energy efficient and sustainable, as well as historic properties 

leased or disposed to parties responsible for their preservation. The ACHP is pleased 

to report that 21 federal agencies submitted reports on or soon after the September 30, 

2014, deadline. In addition to the review of the agency progress reports, the findings and 

recommendations are also informed by the ACHP’s extensive interaction with federal 

agencies and preservation partners on various initiatives over the last three years. 

In assessing the progress federal agencies have made in the last three years, the ACHP 

made four key findings about the current state of federal historic property stewardship: 

1. Integrating historic property stewardship in federal agency strategic planning for 

the consolidation and realignment of real property portfolios improves historic 

preservation outcomes.

2. Agencies would benefit from examples of creative solutions developed for “green 

design” rehabilitation projects of federal historic buildings and structures.

3. Systemic efforts by federal agencies to identify and prepare for the threats of 

climate change and to maximize the resilience of historic properties are important 

stewardship responsibilities.

4. Agency-wide historic preservation policies and leadership commitment to 

their implementation create a culture of stewardship, facilitate the allocation of 

resources to meet responsibilities, and improve preservation outcomes.

EXECUTIVE SUMMARY | 9
The ACHP will work to address these findings through its assistance to federal agencies 

in the Section 106 review process and other daily business and also by implementing 

specific commitments, including the following:

» Continue to provide guidance and success stories demonstrating how highly 

technical and scientific historic properties are adaptively reused by federal agencies.

» Work with the Council on Environmental Quality’s (CEQ’s) Steering Committee 

on Federal Sustainability and collaborate with the General Services Administration 

(GSA) and the National Park Service (NPS) (specifically, the National Center 

for Preservation Technology and Training) to collect stories of successful green 

rehabilitation of historic buildings and structures of all sizes and share them with 

federal agencies.

» Advocate through its participation in the Council on Climate Preparedness and 

Resilience, other related initiatives, and daily activities regarding federal historic 

property stewardship that policy and planning for climate change preparedness 

and resilience adequately address preservation of America’s irreplaceable historic 

properties.

» Encourage other federal agencies to build a preservation program more inclusive of 

the diverse communities and cultures of the nation.

In addition, other federal agencies and non-federal partners should implement applicable 

recommended actions in this report to further current Administration initiatives and 

policies, the goals of EO 13287, and the National Historic Preservation Act (NHPA) 

related to real property management. These recommended actions include the following:

» Federal agencies should request adequate funding to identify historic properties on 

federal land to meet the requirements of Section 110 of the NHPA.

» The Administration should continue its support for and Congress should 

appropriate funding for a national inventory of historic properties to create 

efficiencies in infrastructure permitting and review and to improve environmental 

outcomes both on and off federal land (In FY 2015 Administration Budget; See also 

Budget Data Request No. 13-32: Infrastructure Permitting (2013)).

» Federal agencies should ensure complete and accurate historic property inventory 

data is collected and considered before real property consolidation decisions are 

made, including the decision to leave a historic property unused. 

» The Office of Management and Budget (OMB), in consultation with GSA, the 

ACHP, and other affected agencies, should consider changes to the “Freeze the 

Footprint” offset guidance to increase flexibility for long-term, self-supporting 

Section 111 and Section 412 leases of historic properties to non-federal parties.

» Federal agencies planning and designing energy efficient and sustainable buildings 

and structures, including those seeking Leadership in Energy and Environmental 

Design (LEED) certification, should acknowledge the durability of historic buildings, 

materials, and systems and consider reusing historic properties when feasible.

10 | EXECUTIVE SUMMARY
» The Administration should direct federal agencies to review their existing Climate 

Change and Adaption Plans to identify threats to historic properties and incorporate 

strategies to protect those properties and to maximize their resilience.

The ACHP is committed to assisting federal agencies in implementing these 

recommendations so that future actions proposed by the Administration, departments, 

and agencies recognize historic properties as important public assets by giving 

appropriate consideration when planning for and implementing federal real property 

management strategies that address energy efficiency, sustainability, and climate change.

GSA invested $20 million in a green design rehabilitation of the historic the Sidney Yates Building in Washington, D.C., the National 

Headquarters of the Forest Service.

CREDIT: CAROL M. HIGHSMITH PHOTOGRAPHY, INC./GSA

EXECUTIVE SUMMARY | 11
CHAPTER 1: I NTRODUCTION 

AND BACKGROUND

THE FEDERAL GOVERNMENT IS RESPONSIBLE for the stewardship of 

an immense variety and number of historic properties–including architect-designed 

buildings, landscapes of religious and cultural significance to Indian tribes, highly 

technical properties significant in science and engineering, campuses for federal activities, 

and a vast array of other property types–in all 50 states, the District of Columbia, 

and six U.S. territories. The responsibility for such stewardship was established 

by Congress in 1966 in the National Historic Preservation Act and reinforced by 

subsequent amendments to the Act. In the NHPA and throughout this report, “historic 

properties” are those buildings, structures, objects, sites, and districts that are listed in 

or are eligible for listing in the National Register of Historic Places (NRHP). Among 

those historic properties, some are nationally significant National Historic Landmarks 

(NHLs), designated by the Secretary of the Interior because they possess exceptional 

value or quality in illustrating or interpreting the heritage of the nation. Federal historic 

property stewardship fundamentally includes knowledge about the historic properties 

under federal control through inventory and efforts to protect and continue use of those 

properties so they can benefit the American people. Federal agencies have developed an 

array of protocols to accomplish their federal missions and stewardship responsibilities 

and to achieve a balance when these are in conflict.

The historic Gavins Point 

Dam on the Missouri 

River, Nebraska and South 

Dakota, operated by the 

USACE, continues to provide 

hydroelectric power.

CREDIT: SHUTTERSTOCK
EXECUTIVE ORDER NO. 13287 – PRESERVE AMERICA (2003)

Signed by President Bush on March 3, 2003, Executive Order No. 13287, “Preserve 

America,” reinforces the role of federal agencies as stewards of historic properties in their 

ownership and redoubles the efforts of federal agencies to inventory, protect, and use 

such historic properties. (EO 13287 is reproduced in Appendix A.) The EO emphasizes 

that historic properties are valuable assets to support agency missions, and federal 

investment in them may stimulate local economic development. The EO also introduces 

federal accountability on the stewardship of historic properties in the form of triennial 

reporting. Throughout the EO, the ACHP is called upon to advise and assist federal 

agencies in meeting the EO requirements and to report to the President on progress and 

recommendations for improvements, a role consistent with the ACHP’s mission and 

establishment in the NHPA. An independent federal agency, the ACHP promotes the 

preservation, enhancement, and sustainable use of the nation’s diverse historic resources 

and advises the President and Congress on national historic preservation policy. (The 

membership of the ACHP is detailed in Appendix B.)

The historic preservation stewardship policy in Section 1 of the EO reaffirms the principles 

of the NHPA, as amended, in stating, “The federal government shall recognize and 

manage the historic properties in its ownership as assets that can support department and 

agency missions while contributing to the vitality and economic well-being of the nation’s 

communities.” (The EO uses “agencies” to describe executive branch departments and 

agencies, and this term is used throughout this report.)

Section 2 of the EO focuses on the need for each agency to build preservation partnerships 

consistent with agency missions and governing authorities and to ensure the agency 

encourages, supports, and fosters initiatives and investment in the protection and use of 

historic properties.

Section 3 of the EO required each federal agency “with real property management 

responsibilities” to assess its historic preservation stewardship in a baseline report to the 

ACHP and the Secretary of the Interior by September 30, 2004. In addition, every three 

years thereafter, each agency is required to submit a status report on its progress in these 

areas. Agencies are encouraged to utilize existing reporting systems to prepare this report. 

Section 3(e) of the EO requires the head of each agency to designate a “senior policy 

level official” (SPO) to have policy oversight responsibility for the agency’s historic 

preservation program. This designation must be at the assistant secretary or deputy 

assistant secretary level, or the equivalent, as appropriate to the agency’s organization. 

Section 4 of the EO requires each federal agency to promote the long-term preservation 

and use of historic properties as federal assets and, where consistent with agency missions, 

governing laws, and the nature of the historic properties, contribute to the local community 

and its economy. Agencies are also required to cooperate with communities to increase 

opportunities for public benefit from, and access to, federally owned historic properties. 

As required by Section 4(e), the ACHP submitted to the President and the heads of 

agencies a report Becoming Better Stewards of Our Past: Recommendations for Enhancing 

Federal Management of Historic Properties in March 2004. This report recommended that 

The federal 

government shall 

recognize and manage 

the historic properties 

in its ownership 

as assets that can 

support department 

and agency missions 

while contributing 

to the vitality and 

economic wellbeing of the nation’s 

communities.

EO 13287, “Preserve 

America,” Section 1

CHAPTER 1—INTRODUCTION AND BACKGROUND | 13
PRESERVE AMERICA COMMUNITY AND 

STEWARDS PROGRAMS

Preserve America is a federal program that encourages 

and supports community efforts to preserve and enjoy our 

priceless cultural and natural heritage assets. Established by the 

White House in 2003, the program’s goals include expanding 

knowledge about the nation’s past, strengthening regional 

identities and local pride, increasing public participation 

in preservation, and supporting the economic vitality of 

our communities. The ACHP administers the program in 

cooperation with the National Park Service and the Bureau 

of Land Management, with targeted support from the U.S. 

Forest Service. Other federal agencies, such as the National 

Oceanic and Atmospheric Administration, actively support 

local designations. Since 2004, First Lady Laura Bush and First 

Lady Michelle Obama have designated 895 Preserve America 

Communities and 43 Preserve America Stewards. The community designation portion of the program and the 

Preserve America Grants administered by the NPS were formally authorized by Congress in the Omnibus Public 

Land Management Act of 2009. 

Preserve America Communities protect and celebrate their heritage, use their historic assets for economic 

development and community revitalization, and encourage people to experience and appreciate local historic 

properties through heritage tourism and heritage education. There are three types of Preserve America Communities: 

(1) municipalities or counties with an elected governing official or unincorporated communities within their jurisdiction, 

(2) distinct neighborhoods within large cities or city-counties with a population of 200,000 or greater, or (3) federally 

recognized tribal communities with an elected governing official, or a subdivision of such tribes. 

The Preserve America Stewards program honors exemplary organizations, businesses, or agencies that (1) provide 

volunteers with opportunities to contribute in direct and tangible ways to the preservation, protection, and 

promotion of historic properties; (2) address an otherwise unfilled need in historic preservation through the use 

of volunteer efforts; and (3) demonstrate innovative and creative use of volunteer assistance in areas such as youth 

involvement, volunteer training, public education, and public-private partnerships.

federal agencies (1) partner with non-federal parties, (2) work smart, and (3) enhance the 

preservation ethic in order to stimulate further initiative, creativity, and efficiency in the 

federal stewardship of historic properties.

Section 5 of the EO requires federal agencies to use historic properties in their ownership 

in conjunction with state, tribal, and local tourism programs to foster viable economic 

partnerships, including cooperation and coordination with tourism officials and others 

with interests in the properties. It also directs the Department of Commerce (DOC) 

with the ACHP to assist state, tribal, and local tourism programs to promote the use of 

historic properties for heritage tourism and related economic development in a manner 

that contributes to the long-term preservation and productive use of those properties.

The American Samoa Government and NOAA’s 

Fagatele Bay National Marine Sancutary celebrated 

the territory of American Samoa’s designation as a 

Preserve America Community at Utulei Beach Park, 

Utulei Village, Pago Pago.

CREDIT: NOAA

14 | CHAPTER 1—INTRODUCTION AND BACKGROUND
PREVIOUS SECTION 3 REPORTING

In 2004, federal agencies “with real property management responsibilities” provided 

baseline reports to the ACHP and the Secretary of the Interior assessing the status 

of their inventories of historic properties, general condition and management needs 

of such properties, steps underway to meet such needs, and suitability of the agency’s 

historic properties to contribute to community economic development initiatives 

including heritage tourism. Each report also included a review of the agency’s regulations, 

management policies, and operating procedures for compliance with Sections 110 and 

111 of the NHPA and recommendations to bring them into compliance if needed.

Every third year since, each agency is required to submit a report on its progress in 

these areas. Agencies are encouraged to utilize existing reporting systems to prepare this 

report. The ACHP has posted the progress reports received from agencies at www.achp.

gov/section3. (A table of reports received from 2004 to the present cycle is provided 

in Appendix C.) The ACHP then analyzed the trends in the progress reports and 

made findings and recommendations in triennial reports to the President submitted in 

February 2006, 2009, 2012, and now 2015.

In the third triennial report to the President, submitted in 2012, the ACHP made 

key findings about the current state of federal historic property stewardship and 

recommendations on how agencies can continue to improve their performance in five 

areas: economic development and job creation, sustainability, renewable energy, federal 

real property realignment, and federal agency preservation programs in the 21st century. 

Based on these recommendations, federal stewardship of historic properties progressed 

with the following accomplishments during the current reporting period:

Economic Development and Job Creation

In 2011, the ACHP published Measuring Economic Impacts of Historic Preservation, a 

report reviewing the state of existing knowledge and identifying needs for analytic 

tools prepared by PlaceEconomics with funding from DOC. The study was updated 

and published with other economic impacts studies in 2014 at www.achp.gov/

economicstudies. 

Sustainability

» The ACHP and NPS actively participated in the process led by the U.S. Green 

Building Council to update its LEED certification standards. The resulting LEED 

v. 4, launched in March 2013, includes improved acknowledgement of historic 

significance, materials, and systems.

Renewable Energy

» The ACHP continues to participate actively in the Rapid Response Teams for 

Renewable Energy and Energy Transmission, and other priority infrastructure 

projects resulting in early and coordinated Section 106 compliance for these 

important and complex undertakings.

Section 106 of the 

NHPA (54 U.S.C. 

§ 306108) requires 

agencies to consider 

the effects of projects 

they carry out, license, 

or fund on historic 

properties, and provide 

the ACHP with a 

reasonable opportunity 

to comment on such 

projects. The ACHP has 

issued the regulations 

implementing Section 

106 at 36 C.F.R. 

Part 800.

CHAPTER 1—INTRODUCTION AND BACKGROUND | 15
» The ACHP posted an Applicant Toolkit on its Web site (www.achp.gov/apptoolkit) 

providing easy access to new and existing guidance regarding Section 106, aimed at 

project proponents.

» The ACHP and CEQ jointly published NEPA and NHPA: A Handbook 

for Integrating NEPA and Section 106. (www.achp.gov/docs/NEPA_NHPA_

Section_106_Handbook_Mar2013.pdf)

» The ACHP issued Guidance on Section 106 Agreement Documents. (www.achp.

gov/agreementdocguidance.html)

» The ACHP issued guidance regarding Traditional Cultural Landscapes in the 

Section 106 Review Process. (www.achp.gov/na_culturallandscapes)

» NPS continued its consultation process with federal agencies, State and Tribal 

Historic Preservation Officers, Indian tribes and Native Hawaiian organizations, 

and the public to revise “National Register Bulletin 38: Guidelines for Evaluating 

and Documenting Traditional Cultural Properties.”

Federal Real Property Realignment

» The ACHP provided assistance as requested by the Forest Service (FS) and 

Department of Veterans Affairs (VA) in considering the use of the leasing authority 

under Section 111 of the NHPA. The ACHP continued to collaborate with GSA 

and NPS to encourage federal agencies to use existing federal leasing and reuse 

authorities for historic properties.

» The ACHP briefed the Federal Real Property Council (FRPC) on the role of 

the ACHP, historic property stewardship, and federal compliance responsibilities. 

The ACHP created a work group comprising representatives of federal agencies 

and preservation partners which recommended improvements to the “historical 

status” field of the Federal Real Property Profile (FRPP). All the recommended 

improvements were incorporated in the 2014 edition of the Data Dictionary 

(www.gsa.gov/portal/content/103101).

Federal Agency Preservation Programs in the 21ST Century

» NPS collaborated with the ACHP and other federal agencies to develop 

proposed modifications to the Secretary of the Interior’s Professional 

Qualification Standards. 

Among other things, 

Section 111 of the 

NHPA (54 U.S.C. 

§ 306121) authorizes 

an agency to lease a 

historic property if it 

determines the lease 

will adequately ensure 

the preservation of 

the property. The 

agency may retain 

and use the proceeds 

of the lease to 

defray the costs of 

the administration, 

maintenance, repair, 

and related expenses 

of that property 

or other historic 

properties that it 

owns or that are 

under its jurisdiction 

or control.

16 | CHAPTER 1—INTRODUCTION AND BACKGROUND
In 2011, NASA entered into a 

Programmatic Agreement with the ACHP 

and the State Historic Preservation 

Officers (SHPOs) of Alabama, California, 

Florida, and Texas for the retirement of 

the Space Shuttle Orbiters from service. 

The orbiters were extensively recorded by 

the Historic American Engineering Record 

(HAER) using not only traditional line 

drawings and large format photographs 

but also new techniques. For example, 

HAER posted its video illustrating a 

point-cloud fly-through of Discovery on 

YouTube.com. Now preserved for future 

generations, the three historic active 

orbiters are now accessible to the public:

» Atlantis at the Kennedy Space Center, 

Florida; 

» Discovery at the Smithsonian’s 

National Air and Space Museum 

Annex, Virginia; and 

» Endeavour at the California Science 

Museum.

The three orbiters are big museum draws. 

The Smithsonian’s National Air and Space 

Museum continues to be the single most 

visited museum in the U.S., while the 

new Space Shuttle Atlantis display at the 

Kennedy Space Center has resulted in a 

20 percent increase in visitors to more 

than 1.5 million annual visitors.

In addition to the historic space shuttles, 

NASA has also been reconfiguring 

and repurposing other facilities and 

infrastructure that supported the launch 

and missions of the shuttles. These include 

the Shuttle Avionics and Integration 

Laboratory (SAIL) at the Johnson Space 

Center, NASA’s only facility where the 

actual orbiter hardware and mission 

software could be tested in a simulated 

flight environment. It included an exact 

mock-up of a cockpit of a shuttle 

for realistic testing. The SAIL facility 

carried out complete shuttle simulated 

ground testing and countdown and 

abort operations of an actual flight. The 

SAIL facility was saved from scheduled 

demolition and transitioned to be part of 

the Johnson Space Center visitor center 

experience. 

Kennedy Space Center’s Launch Pad 39A, 

another historic facility associated with the 

space shuttle program, is also preserved 

and now leased to SpaceX for its 

commercial Falcon Heavy rocket launches. 

Just as the gantry service structures were 

extensively modified from the Saturn 

program to launch the space shuttles, the 

pad will again be modified to launch the 

SpaceX rocket. SpaceX will pay for the 

overall costs of maintenance during the 

20-year lease term.

Space Shuttle Atlantis Exhibit at Kennedy Space Center, Florida, provides public access to the 

historic structure.

CASE STUDY

Retirement of the 

Space Shuttle 

Program as a Gift 

to the American 

People

FEDERAL AGENCY

National Aeronautics and Space 

Administration (NASA)

LOCATION 

Alabama, California, Florida, 

Texas, and Virginia

CREDIT: NASA

The historic Launch Pad 39A at Kennedy Space 

Center, Florida, was no longer needed by NASA when 

the Space Shuttle program was retired. The site is now 

leased for commercial space use.

CREDIT: NASA

CHAPTER 1—INTRODUCTION AND BACKGROUND | 17
FRAMEWORK FOR 2015 REPORT TO THE PRESIDENT

The ACHP will continue to use the five thematic areas, as established in the 2012 Report 

to the President, to organize its findings and recommendations for progress in meeting 

the goals of the Preserve America EO.

Enhancing and Improving Inventories of Historic Properties

An accurate, comprehensive inventory and evaluations of an agency’s historic properties 

are the foundation for understanding these assets, their management needs and goals, 

and economic potential. Opportunities to address inventory funding, databases, and 

meeting the requirements of Sections 106 and 110 of the NHPA are considered under 

this theme.

Integrating Stewardship into Agency Planning 

Considering historic preservation goals in an agency’s strategic plans can open 

opportunities for historic properties to be part of the solution rather than the problem. 

Opportunities to address agency policies and procedures, consolidation, master planning, 

leasing and other cost sharing approaches, demolition and disposal, and climate change 

are included in this theme.

Managing Assets

Establishing procedures to balance the consideration of historic property protection and 

use with an agency’s mission will allow an agency to comply fully with the NHPA and 

EO 13514. Opportunities to address reuse of highly technical properties, rehabilitation 

for improved sustainability, and other management accomplishments are addressed in 

this theme.

Contributing to the Economy

Local and regional economic development and heritage tourism can be promoted 

through a variety of agency activities and collaborative ventures. Opportunities to identify 

examples of agency programs and projects with reported measureable economic effects 

are considered in this theme.

Building Partnerships

Public-private partnerships, when consistent with agency missions, can be effective 

in caring for historic properties, engaging volunteers, educating the public, promoting 

economic development and heritage tourism, and lessening federal costs. This theme 

highlights examples of public-private partnerships that accomplish the goals of EO 

13287.

18 | CHAPTER 1—INTRODUCTION AND BACKGROUND
CHAPTER 2: CURRE NT S TATE OF 

REAL PROPERTY MANAGEMENT

THE SUBMITTED SECTION 3 PROGRESS REPORTS confirm that federal 

agencies in this reporting cycle, 2012-2015, remain focused on managing real property 

assets, including historic properties, to maximum advantage: seeking opportunities to 

generate federal revenue through leasing and disposal, minimize life-cycle costs, and 

improve energy efficiency and sustainability. Agencies also are seeking administrative 

improvements to the permitting process for infrastructure projects. Agencies began 

preparing for the effects of climate change, recovering from the effects of emergencies 

and disasters such as Hurricane Sandy, and working to develop a Unified Federal Review 

process for such future events. These efforts were spurred by Administration policies and 

initiatives, some established prior to the 2012 Report to the President and some since. 

CONTINUING POLICIES AND INITIATIVES

The 2012 Report to the President discussed several policies and initiatives that have 

continued to influence federal real property management in the current reporting cycle 

regarding disposal of unneeded property, energy efficiency and sustainability, and federal 

permitting and review of infrastructure projects. The key components of each and 

updates on relevant ACHP actions during the reporting cycle regarding these items are 

discussed below.

WWII Pillboxes before 

restoration by BOR in 

Hoover Dam National 

Historic Landmark, Nevada

CREDIT: BOR
Executive Order No. 13514 – Federal Leadership 

in Environmental, Energy, and Economic Performance (2009)

EO 13514 established a number of policies, including that federal agencies increase 

energy efficiency and that they design, construct, maintain, and operate high performance 

sustainable buildings in sustainable locations. (www.gpo.gov/fdsys/pkg/FR-2009-10-08/

pdf/E9-24518.pdf) Fulfilling the requirements of Section 2(g) of the EO, in 2011 the 

ACHP, with the support of CEQ, issued “Sustainability and Historic Federal Buildings: 

Integrating the Requirements of the National Historic Preservation Act with the 

Requirements of Executive Order 13514: Federal Leadership in Environmental, Energy, 

and Economic Performance.” In this guidance, the ACHP recommended the following 

approach to decision making regarding federal historic buildings: 

» Consider reusing a historic building before constructing a new building or leasing 

space in a privately owned building, 

» Rehabilitate a historic building by using, reclaiming, and enhancing historic 

sustainable features and by adding compatible sustainability improvements when 

needed, 

» Design compatible new green construction in existing historic communities when 

needed, and 

» Consider disposing of a historic building only after other options are appropriately 

considered.

One hallmark of highly green design is LEED certification by the U.S. Green Building 

Council. There are four levels of certification (from least to most green): Certified, 

Silver, Gold, and Platinum. In this reporting cycle, the ACHP and NPS fulfilled the 

recommendation in the 2012 Report to the President by actively commenting on the 

LEED standards revision. The resulting LEED v. 4, launched in March 2013, includes 

improved acknowledgement of historic significance, materials, and systems in the 

certification standards.

Green design, however, does not require LEED certification. Federal agencies are 

incorporating green design solutions, with or without LEED certification, in a wide 

variety of new construction and rehabilitation projects, including new construction in 

historic districts and the rehabilitation of historic buildings and structures for continued 

productive use.

Presidential Memorandum – Disposing of Unneeded Federal Real 

Estate—Increasing Sales Proceeds, Cutting Operating Costs, and 

Improving Energy Efficiency (2010)

In this Presidential Memorandum, the Administration directed agencies “to accelerate 

efforts to identify and eliminate excess properties,” as a means to eliminate wasteful 

spending of taxpayer dollars, save energy and water, and further reduce greenhouse gas 

pollution. (www.gpo.gov/fdsys/pkg/DCPD-201000483/pdf/DCPD-201000483.pdf) 

In the period from Fiscal Years 2010 through 2012, the agency efforts were expected 

Each federal agency 

shall implement 

high performance 

sustainable federal 

building design, 

construction, 

operation and 

management, 

maintenance, and 

deconstruction.

EO 13514, Section 2(g)

20 | CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT 
Although USPS has disposed of post 

offices throughout its history, the rate 

of disposals has increased since 2008. 

Declining mail volumes, increased 

automation of mail sorting, and increased 

worker productivity have led USPS to 

determine that many post offices are 

larger than needed. Declining revenues 

have also forced the self-supporting 

agency to pursue opportunities to 

decrease costs, including those incurred 

through the operation and maintenance 

of its post offices. Inevitably, USPS has 

determined that many of its post offices 

are unneeded and ripe for disposal at 

this time.

However, Section 106 consultations on a 

number of high-profile disposals across 

the country have demonstrated that the 

historic preservation community and the 

public have significant concerns about the 

potential closure of these iconic buildings, 

including the loss of public use of the 

buildings, the risk posed to the historic 

architecture and art, and the potential 

loss of public access to these places of 

importance to local communities. State 

Historic Preservation Officers and local 

communities have expressed concern 

not only that the post offices will be 

closed, but also have cited as problematic 

the manner in which USPS conducts its 

decision-making process, the transparency 

of that process, and how it meets the 

requirements of Section 106.

Responding to significant public concerns 

about widespread closure of historic post 

offices, Congress directed the ACHP 

to report on the compliance of USPS 

with Section 106 of the NHPA for these 

properties (Explanatory statement of the 

Consolidated Appropriations Act of 2014, 

Division G). 

The ACHP provided Congress with 

Preserving Historic Post Offices: A Report to 

Congress in April 2014, including findings 

and recommendations for USPS to 

improve compliance with Section 106 

while building collaborative relationships 

with communities and historic 

preservation stakeholders. The ACHP 

emphasized that USPS awareness of and 

appreciation for the value of historic post 

offices as important community resources 

under federal ownership can foster better 

management practices that will benefit 

USPS, the historic properties, and the 

communities in which they reside.

In a specific case, which illustrates some 

of the challenges discussed in the report, 

USPS initiated Section 106 consultation 

regarding the proposed transfer of 

the Burlingame Main Post Office to 

the City of Burlingame, California, after 

deciding to relocate postal services from 

the building. The historic post office, 

constructed between 1930 and 1942, 

is associated with and embodies the 

USPS completed the Section 106 process and transferred the Burlingame Post Office in 

California to the City of Burlingame with a preservation covenant to ensure its long-term 

preservation and no adverse effect to the historic property.

CASE STUDY

Historic Post Office 

Disposals

FEDERAL AGENCY

U.S. Postal Service (USPS)

LOCATION 

Nationwide

CREDIT: USPS

CHAPTER 1—INTRODUCTION AND BACKGROUND | CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT | 21 21
distinctive characteristics of New Deal 

federal architecture in the Spanish Eclectic 

and Spanish Colonial Revival Styles. The 

interior of the post office retains original 

features such as marble wainscoting, 

original post office boxes, metal-trimmed 

bulletin boards, and service desks. While 

many historic post offices contain murals, 

this one does not.

USPS proposed that the transfer of the 

historic property out of federal control 

would include a historic preservation 

covenant, which the agency believed 

would ensure the long-term preservation 

of the historic property. Accordingly, the 

agency proposed that the undertaking 

would have no adverse effect to the 

historic post office. However, the State 

Historic Preservation Officer and other 

consulting parties objected to the 

inclusion of a clause in the covenant 

stating that, “the City may, for good 

cause, and following notice to the 

public, modify or cancel any or all of the 

foregoing restriction upon application 

for the grantee, its heir and successor, 

or assigns.” The parties were concerned 

that long-term preservation was not, in 

fact, ensured, if the City could modify 

or cancel the protective covenant “for 

good cause.” Initially, USPS did not wish 

to consider alterations to this clause on 

the grounds that it was standard language. 

With technical assistance from the ACHP 

and through continued consultation with 

the consulting parties, USPS determined 

that it was appropriate to strike the clause 

in order to reach agreement that the 

undertaking, with the revised covenant, 

would not adversely affect the historic 

post office.

The Burlingame Post Office represents 

the successful conclusion of the Section 

106 process for one historic postal facility. 

However, covenants have not proven 

to be the best solution for all disposals. 

When entities willing or able to enforce 

covenants are not readily available or 

reuse options for the historic property 

are limited, challenges remain for USPS 

and local communities. In the 2014 

Report to Congress, the ACHP identifies 

a number of opportunities for USPS, the 

ACHP, and other preservation partners 

to work collaboratively to address these 

challenges and strive for better community 

outcomes. Creative and cooperative 

approaches focused on long-term 

preservation and economic development 

offer opportunities for both USPS and 

local communities to identify solutions that 

address everyone’s interests.

The ACHP issued Preserving Historic 

Post Offices: A Report to Congress on 

April 17, 2014. 

22 | CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT
Agencies reported 

real property cost 

savings of $3.8 

billion in response 

to the Presidential 

memorandum 

from disposal, 

space management, 

sustainability, and 

innovation activities.

to produce no less than $3 billion in cost savings, realized through increased proceeds 

from the sale of assets and reduced operating, maintenance, and energy expenses from 

disposals or other space consolidation efforts, including leases that were ended. Many of 

the disposed properties included historic buildings, structures, objects, sites, and districts.

Agencies reported real property cost savings of $3.8 billion in response to the Presidential 

memorandum from disposal, space management, sustainability, and innovation activities. 

The Government Accountability Office (GAO) audited the agency reports and published 

GAO-14-12, “Federal Real Property: Improved Standards Needed to Ensure That 

Agencies’ Reported Cost Savings Are Reliable and Transparent” on October 29, 2013. 

GAO’s review of the six selected agencies identified several problems that affect the 

reliability and transparency of the reporting of cost savings in response to the June 2010 

memorandum. In particular, the memorandum and subsequent guidance issued by OMB 

were not clear on the types of savings that could be reported, particularly because the 

term “cost savings” was not clearly defined. Further, OMB did not require agencies to 

provide detailed documentation of their reported savings or include specific information 

about agencies’ reported savings on Performance.gov, limiting transparency. GAO 

recommended that the Director of OMB establish clear and specific standards to help 

ensure reliability and transparency in the reporting of future real property cost savings. 

OMB generally agreed with GAO’s recommendation.

While the term of the policy only includes seven months in the current reporting period, 

the effects of this policy have continued as its goals have been incorporated into new 

policies and initiatives, most especially “Freeze the Footprint,” discussed below.

Executive Order No. 13604 – Improving Federal Performance of 

Federal Permitting and Review of Infrastructure Projects (2012)

As described in the 2012 Report to the President, a Presidential Memorandum issued in 

2011 titled, “Speeding Infrastructure Development through More Efficient and Effective 

Permitting and Environmental Review,” required the Departments of Agriculture, 

Commerce, Housing and Urban Development, the Interior, and Transportation to 

identify high-priority permitted infrastructure projects to be expedited through the 

permitting and environmental review process. (www.gpo.gov/fdsys/pkg/DCPD201100601/pdf/DCPD-201100601.pdf) ACHP senior staff participated in the 

resulting “Rapid Response Teams” formed to monitor the project review processes. 

The ACHP also formally participated in the Section 106 review of many of the 

subject projects to aid the permitting agency and other participants in the process in 

understanding the requirements of the Section 106 process, its inherent flexibility, 

project-appropriate means to expedite the process, and strategies for successfully reaching 

agreement among the consulting parties.

The Presidential Memorandum also instructed agencies to implement new measures 

to improve the accountability, transparency, and efficiency of the permitting and 

environmental review processes through the use of modern information technology. 

This idea was later transferred and expanded upon in EO 13604, “Improving Federal 

Performance of Federal Permitting and Review of Infrastructure Projects,” issued in 

2012. (www.gpo.gov/fdsys/pkg/FR-2012-03-28/pdf/2012-7636.pdf) EO 13604 directs 

CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT | 23
agencies “to execute federal permitting and review processes with maximum efficiency 

and effectiveness, ensuring the health, safety, and security of communities and the 

environment while supporting vital economic growth.” It further directs agencies that the 

federal permitting and review processes must:

» Provide a transparent, consistent, and predictable path for project sponsors and 

affected communities

» Set and adhere to timelines and schedules

» Set clear permitting performance goals and track progress against those goals

» Encourage early collaboration among agencies, project sponsors, and affected 

stakeholders

» Provide for transparency and accountability by utilizing cost-effective information 

technology to collect and disseminate information

» Rely upon early and active consultation with state, local, and tribal governments

» Recognize the critical role project sponsors play

» Enable agencies to share priorities, work collaboratively and concurrently to advance 

reviews and permitting decisions, and facilitate the resolution of disputes at all levels 

of agency organization.

Section 2 of the EO established the Steering Committee on Federal Infrastructure 

Permitting and Review Process Improvement to develop and implement a Performance 

Plan. The ACHP is a member of this Steering Committee.

The ACHP reviewed the process defined in the regulations implementing Section 

106 of the NHPA, “Protection of Historic Properties” (36 CFR Part 800). The 

agency determined that the process, founded on consultation among a federal agency 

and affected stakeholders including Indian tribes and project sponsors, addressed 

the requirements of the EO and did not need revision. However, the need for more 

explanatory materials regarding the coordination of the requirements of Section 106 

with those of the National Environmental Policy Act (NEPA) and the role of project 

sponsors in the process were identified. In March 2013, the ACHP and CEQ jointly 

published NEPA and NHPA: A Handbook for Integrating NEPA and Section 106, 

accomplishing one of the recommendations in the 2012 Report to the President. In 

addition, in September 2013, the ACHP launched the “Applicant Toolkit” on its Web 

site as a living collection of explanatory materials about the Section 106 process in 

general and the role of project sponsors (“applicants,” in the Section 106 process). In 

October 2014, the ACHP also posted “Guidance on Agreement Documents” on its Web 

site providing assistance to all participants in developing, implementing, and concluding 

Section 106 agreements.

NEW GUIDANCE 

AVAILABLE AT 

WWW.ACHP.GOV:

Traditional Cultural 

Landscapes in the Section 

106 Review Process, March 

2012

Traditional Cultural 

Landscapes in the Section 

106 Review Process: 

Questions and Answers, 

July 2012

NEPA and NHPA: A 

Handbook for Integrating 

NEPA and Section 106, 

March 2013

The Applicant Toolkit, 

September 2013

Guidance on Agreement 

Documents, October 2014

24 | CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT
One of the historic preservation issues in the planning for many large infrastructure 

projects is the identification and protection of traditional cultural landscapes of religious 

and cultural significance to Indian tribes and Native Hawaiian organizations. Such 

historic properties may be located entirely or in part within federal lands, especially 

those owned by the Bureau of Land Management (BLM) and FS. Fulfilling the 

recommendation from the 2012 Report to the President, the ACHP continued to 

implement its Native American Traditional Cultural Landscapes Action Plan, adopted 

in November 2011. In 2012, the ACHP published, “Traditional Cultural Landscapes in 

the Section 106 Review Process,” and “Native American Traditional Cultural Landscapes 

and the Section 106 Review Process: Questions and Answers.” The NPS has also been 

working to update its guidance, “National Register Bulletin 38: Guidelines for Evaluating 

and Documenting Traditional Cultural Properties,” another recommendation from the 

2012 Report to the President.

NEW POLICIES AND INITIATIVES

Since the 2012 Report to the President, the Administration policies regarding disposal 

and sustainability of federal buildings and structures converged in a new policy known as 

“Freeze the Footprint.” At the same time, federal agencies began preparing for the effects of 

climate change, recovered from the effects of emergencies and disasters such as Hurricane 

Sandy, and worked to develop a Unified Federal Review process for such future events.

OMB Memorandum M-12-12 – Promoting Efficient Spending to 

Support Agency Operations and “Freeze The Footprint” (2012)

According to the OMB Memorandum (www.whitehouse.gov/sites/default/files/omb/

memoranda/2012/m-12-12.pdf) and subsequent guidance in OMB Management 

Procedures Memorandum 2013-02, “Implementation of OMB Memorandum M-12-12 

Section 3: Freeze the Footprint,” (2013), a federal agency shall not increase on an annual 

basis the size of its domestic real estate inventory, measured in square footage, for space 

predominantly used for offices and warehouses. (www.whitehouse.gov/sites/default/

files/omb/financial/memos/implementation-of-freeze-the-footprint-guidance.pdf) Any 

growth in total office or warehouse space must be offset by a corresponding decrease 

through declaration of excess, disposal, or closed/realigned as part of a Department 

of Defense (DOD) Base Realignment and Closure (BRAC) process. An agency may 

not use as an offset properties that the agency has “mothballed” or those subject to 

enhanced use leases (EULs) and outleases, even when leases present opportunities to 

leverage federal resources through private investment and public-private partnerships. 

OMB recommends that agencies work collaboratively with other agencies and GSA for 

opportunities to co-locate or consolidate that will result in no net growth of the overall 

federal real estate inventory.

A federal agency 

shall not increase on 

an annual basis the 

size of its domestic 

real estate inventory, 

measured in square 

footage, for space 

predominately 

used for offices and 

warehouses.

CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT | 25
Executive Order No. 13653 – Preparing the United States for the 

Impacts of Climate Change (2013)

Building on the imperatives outlined in EO 13514 “Federal Leadership in Environmental, 

Energy, and Economic Performance” (2009), EO 13653 directs the federal government 

to pursue new strategies to improve the nation’s preparedness and resilience to climate 

change. (www.gpo.gov/fdsys/pkg/FR-2013-11-06/pdf/2013-26785.pdf) Agencies 

should promote:

» Engaged and strong partnerships and information sharing at all levels of government;

» Risk-informed decision making and the tools to facilitate it;

» Adaptive learning, in which experiences serve as opportunities to inform and adjust 

future actions; and 

» Preparedness planning.

The EO directs agencies to work with CEQ and OMB to complete an inventory 

and assessment of proposed and completed changes to their land- and water-related 

policies, programs, and regulations necessary to make watersheds, natural resources and 

ecosystems, and the communities and economies that depend on them more resilient to 

climate change. Section 5 of the EO requires agencies to develop or continue to develop, 

implement, and update comprehensive plans that integrate consideration of climate 

change into agency operations and overall mission objectives, including the following:

» identification and assessment of climate change-related impacts on and risks to the 

agency’s ability to accomplish its missions, operations, and programs;

» a description of programs, policies, and plans the agency has already put in place, as 

well as additional actions the agency will take, to manage climate risks in the near 

term and build resilience in the short and long term;

» a description of how any climate change-related risk identified that is deemed 

so significant that it impairs an agency’s statutory mission or operation will be 

addressed, including through the agency’s existing reporting requirements;

» a description of how the agency will consider the need to improve climate adaptation 

and resilience, including the costs and benefits of such improvement, with respect 

to agency suppliers, supply chain, real property investments, and capital equipment 

purchases such as updating agency policies for leasing, building upgrades, relocation 

of existing facilities and equipment, and construction of new facilities; and 

» a description of how the agency will contribute to coordinated interagency 

efforts to support climate preparedness and resilience at all levels of government, 

including collaborative work across agencies’ regional offices and hubs, and through 

coordinated development of information, data, and tools.

In addition, the EO establishes a Council on Climate Preparedness and Resilience to 

work across agencies and with state, local, and tribal governments; academic and research 

institutions; and private and nonprofit sectors to develop and implement actions related 

26 | CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT
to climate preparedness and resilience; support state, local, and tribal actions to address 

the impacts of climate change; and facilitate the integration of science-based climate 

information into policies and planning at all levels. The ACHP participates in the 

Council on Climate Preparedness and Resilience established by EO 13653.

Sandy Recovery Improvement Act of 2013, “Unified Federal Review”

In October 2012, Hurricane Sandy damaged hundreds of thousands of homes, forced 

tens of thousands of survivors into shelters, and caused billions of dollars in damage 

to vital infrastructure systems including power transmission, transportation, and water 

and sewage treatment facilities. As a direct result of the storm, 73 people in the U.S. lost 

their lives. In accordance with the Robert T. Stafford Disaster Relief and Emergency 

Assistance Act (Stafford Act), the President made Major Disaster Declarations for 14 

states.

Typically in disaster and emergency situations, state, tribal, territorial, and local 

governments who applied for assistance to recover from damage caused by a disaster were 

required to submit their recovery projects to several federal agencies for environmental 

and historic preservation reviews. Often the same data was required from various 

agencies to comply with the legal requirements. To improve the review process, Congress 

passed the Sandy Recovery Improvement Act, which added Section 429 to the Stafford 

Act, governing disaster recovery assistance. The new section directed the President, in 

consultation with CEQ and the ACHP, “to establish an expedited and unified interagency 

review process to ensure compliance with environmental and historic requirements under 

federal law relating to disaster recovery projects, in order to expedite the recovery process, 

consistent with applicable law.”

Development of the Unified Federal Environmental and Historic Preservation Review 

process was led by a Steering Group consisting of CEQ, Department of Homeland 

Security (DHS), Federal Emergency Management Agency (FEMA), and the ACHP 

and a larger working group that included representation from diverse agencies who 

continue to work on identifying ways to enhance efficiencies in environmental and 

historic preservation reviews. 

The goal of the process is to formalize and standardize the unification of regulatory 

requirements so that agencies can take advantage of the same project approval 

mechanisms and resources to expedite reviews necessary for more timely decisions 

on disaster recovery projects. Federal agencies must satisfy their own requirements 

and coordinate with each other when an applicant’s project requires decisions from 

multiple agencies. When interagency coordination is successful, agency decision making 

is improved, resources are conserved, and duplication of analyses are avoided so that 

agencies may support community resiliency and expedite the recovery process.

The Steering Group also continues to coordinate its work with other interagency efforts, 

such as the Federal Infrastructure Permitting and Review Process Improvement Working 

Group (EO 13604, discussed above) and the Hurricane Sandy Task Force (EO 13632, 

“Establishing the Hurricane Sandy Rebuilding Task Force,” 2012), in instances where the 

efforts of these various groups are focused on similar or related topics and issues. Such 

CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT | 27
coordination is intended to help the groups leverage existing efforts being undertaken 

by others, avoid redundant efforts across the various groups, and keep the focus on 

environmental and historic preservation compliance.

BUILDING A MORE INCLUSIVE PRESERVATION PROGRAM

The changing demographics of America pose opportunities as well as challenges for the 

national historic preservation program. The diversity of cultures in the U.S. shape and 

enrich the American experience, and the federal government can continue to encourage 

wider involvement and representation in determining what historic sites are worthy 

of recognition and preservation; how history and cultural heritage should be valued, 

interpreted, and preserved; and how the American public as a whole can take advantage 

of the programs and tools created under the NHPA. 

The ACHP is committed to building a more inclusive preservation program in all aspects 

of its work, in accordance with an initiative adopted by the membership in 2013. In order 

to achieve this goal, the ACHP continually encourages the meaningful involvement of 

the diverse public and interested parties in the identification, evaluation, and protection 

of historic properties through its participation in the Section 106 review process and 

its other daily business. Information about “preservationists in the neighborhood;” 

opportunities for youth, teachers, and community involvement; examples of model 

inclusiveness programs; and preservation partner activities are posted on the Web site.

(www.achp.gov/inclusiveness)

Similarly, the NPS is committed to connecting and amplifying all Americans’ stories 

throughout national parks and communities across the U.S. Current National Park 

Service Heritage Initiatives explore the rich and diverse legacy of all Americans: the 

American Latino Heritage; Asian American Pacific Islander; Women’s; and Lesbian, Gay, 

Bisexual, and Transgender Heritage Initiatives. The NPS plan for the agency’s centennial 

“A Call to Action: Preparing for a Second Century of Stewardship and Engagement” 

includes several objectives to build a more inclusive preservation program:

» Fill in the Gaps–Identify a national system of parks and protected sites (rivers, 

heritage areas, trails, and landmarks) that fully represents our natural resources and 

the nation’s cultural experience. 

» History Lesson–Excite and involve new audiences in the exploration of the full 

diversity of the American experience by conducting history discovery events, projects, 

and activities that invite them to explore and share their heritage, using a variety of 

participatory methods, in at least 100 parks and programs.

» Stop Talking and Listen–Learn about the challenges and opportunities associated 

with connecting diverse communities to the great outdoors and our collective 

history. To accomplish this, the NPS will conduct in-depth, ongoing conversations 

with citizens in seven communities, one in each NPS Region, representing broadly 

varied cultures and locations. The NPS will create and implement work plans at 

each location, which explore new approaches for building and sustaining mutually 

beneficial relationships with diverse communities.

Students in the Urban Archeology 

Program sift for artifacts at a national park 

in the National Capital Region.

CREDIT: NPS

28 | CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT
NPS also develops publications, sponsors internships, funds research projects, distributes 

information about diverse cultures and the historic places significant to them, and 

sponsors conferences. For more information, see the NPS Web site. (www.nps.gov/crdi) 

These efforts underscore the important role that federal agencies can and must play in 

expanding opportunities for all Americans to engage in the federal preservation program. 

50th ANNIVERSARY OF THE NATIONAL HISTORIC 

PRESERVATION ACT

In 2016, the NHPA will celebrate its 50th birthday. Section 1 of EO 13287 reaffirms 

the major principles of the NHPA policy by recognizing that federal agencies should 

manage federal historic properties in a manner that supports “the department and 

agency missions while contributing to the vitality of the economic well-being of the 

nation’s communities and fostering broader appreciation for the development of the 

United States and its underlying values.” This anniversary presents an opportunity to 

identify long-term policy priorities and objectives to ensure federal historic preservation 

leadership continues into the next 50 years and beyond.

CORRELATION TO AGENCIES’ SECTION 3 PROGRESS REPORTS

Taken together, these Administration policies and initiatives seek to improve the 

transparent, efficient, and cost-effective management of federal real property. Agencies 

have expanded opportunities for historic properties to be a part of the energy efficient 

and sustainable solution to federal property needs. However, despite the general trend 

toward improvement, agencies continue to face many challenges in balancing historic 

preservation and real property management needs that were reported by the ACHP in 

2009 and 2012:

» Limited resources to support historic property identification, condition assessments, 

maintenance, and capital improvement projects;

» Lack of accurate and available information regarding the presence and value of 

historic assets in the agency’s real property portfolio;

» Existence of conflicting regulations and directives regarding the management and 

disposal of real property assets; and

» Lack of agency experience with and guidance on creative strategies for using historic 

properties to support agency missions.

In the following chapters, the ACHP will summarize the agency progress reports 

submitted and provide findings and recommendations for actions to continue to improve 

the stewardship of historic properties under federal ownership.

Despite the general 

trend toward 

improvement, 

agencies continue to 

face many challenges 

in balancing historic 

preservation and 

real property 

management needs 

that were reported 

by the ACHP in 2009 

and 2012.

CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT | 29
CHAPTER 3: CURRE NT S TATE 

OF F E DE R AL S T EWAR D SH I P

AS FEDERAL AGENCIES REMAIN FOCUSED on managing real property 

assets, including historic properties, to maximum advantage, the requirements to identify, 

protect, and use historic properties under their ownership sometimes complement 

and sometimes conflict with those property management efforts. The progress reports 

submitted in 2014 demonstrate that federal agencies are continuing to improve and 

diversify the development and application of tools, strategies, and partnerships to achieve 

the objectives of EO 13287.

In 2004, federal agencies “with real property management responsibilities” provided 

baseline reports to the ACHP and the Secretary of the Interior as required by the 

Preserve America EO. In 2005, 2008, 2011, and 2014 each agency was required to 

submit a report on its progress in these areas. Agencies were encouraged to utilize 

existing reporting systems to prepare this report. The ACHP has posted the progress 

reports received from agencies at www.achp.gov/section3. 

The number of progress reports continues to fluctuate each cycle. Agencies may elect not 

to submit progress reports because the provisions in EO 13287 do not apply to them as 

they do not own real property. Individual bureaus may elect to submit separate progress 

reports one cycle but consolidated reports with their parent agency or department 

in another reporting cycle. While the ACHP provided its “Advisory Guidelines 

Implementing Section 3: Reporting Progress on the Identification, Protection, and Use 

PROGRESS REPORTS SUBMITTED,

2005–2014

See Appendix C for a complete list of 

Section 3 reports submitted, 2004–2014.

The DHS Directorate for 

Science and Technology 

partners with lighthouse and 

military enthusiasts to allow 

exterior tours of the historic 

Plum Island Lighthouse and 

Fort Terry, New York. 

COPYRIGHT: LEE SNIDER PHOTO IMAGES

2005 2008 2011 2014

23 21 21

24
of Federal Historic Properties” (Appendix D), some agencies elected to address the 

questions in the advisory, and not mandatory, guidelines while others did not. As a result 

of these variables, the quantity and quality of the reporting fluctuates and can result in 

challenges for the ACHP to identify consistent data and trends. But general trends are 

nonetheless apparent and discussed here in the framework outlined in Chapter 1.

INVENTORIES OF HISTORIC PROPERTIES

An accurate, comprehensive inventory and evaluations of an agency’s historic properties 

are the foundation for understanding these assets, management needs and goals, and 

economic potential. In the reporting cycle, federal agencies reported incremental 

advancement in the collection of new inventory data but substantial improvement in the 

management and usefulness of inventory data.

FUNDING

Since 2004, federal agencies have reported challenges in achieving an accurate, 

comprehensive inventory of historic assets under their control as required by Section 110 

of the NHPA and supported by EO 13287. The primary challenge to achieving this goal 

is funding. Many agencies have a small budget for their historic preservation program, 

and those budgets have often been limited even further by budget constraints in recent 

years. As an example, the Federal Bureau of Prisons (BOP) reports that no identification 

studies under Section 110 have been initiated during the reporting cycle and that its major 

challenge is a lack of funding to address its institutions that are 50 years of age or older. 

Echoing the comments of the BOP, the Bureau of Indian Affairs (BIA) reports that 

reductions in program funding and the 2013 sequestration have further restricted the 

agency’s ability to inventory and evaluate historic structures. In 2013, it issued a single 

contract to evaluate a group of buildings on the Navajo Reservation; no other contracts 

were issued in the past three years.

Even agencies with substantial federal historic preservation programs, supported by both 

appropriated and non-appropriated funds, have felt budget restrictions in recent years. 

The BLM reported in detail on its declining funding through the cycle.

FEDERAL REAL PROPERTY PROFILE AND OTHER DATABASES

Agencies have benefitted in this reporting cycle from attention to reporting standards for 

historic properties, especially buildings and structures. In June 2012, the GAO published 

GAO-12-645, “Federal Real Property: National Strategy and Better Data Needed to 

Improve Management of Excess and Underutilized Property.” The GAO found that the 

FRPC has not followed sound data collection practices in designing and maintaining the 

FRPP database, raising concern that the database is not a useful tool for describing the 

nature, use, and extent of excess and underutilized federal real property. While GAO did 

not highlight difficulties specific to the “historical status” field of the FRPP, the ACHP, 

GSA, and other agencies took note of the report and identified the FRPP’s shortcomings 

as potential impediments to sound decision making and the stewardship of historic 

buildings and structures.

BLM CULTURAL RESOURCES 

MANAGEMENT PROGRAM FUNDING

Deferred Maintenance/Capital 

Improvement Program Appropriated 

Funds

Challenge Cost Share Appropriated/

Cooperative Management Agreements 

Non-Appropriated Funds

Cultural Resource Program 

Appropriated Funds

$18.7M $16.8M $16.4M

FY2011 FY2012 FY2013

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 31
In December 2012, GAO explored this concern further and published GAO-13-

35, “Federal Real Property: Improved Data Needed to Strategically Manage Historic 

Buildings, Address Multiple Challenges.” In this audit of GSA, NPS, and VA, GAO 

found that data on historic buildings in the FRPP were incomplete and inconsistent and 

that these data flaws compounded the agencies’ challenges to manage historic buildings 

in their portfolios. GAO recommended that GSA (Office of Government-wide Policy) 

collaborate and consult with NPS, VA, FRPC member agencies, and others to address 

the need for improved data on historic buildings in the FRPP. GSA agreed with GAO’s 

recommendation and began corrective action before the report was published. 

Responding to this call to action and implementing recommendations of the 2012 

Section 3 Report to the President, the ACHP created a work group to address these 

concerns. Comprising representatives of GSA (Public Building Service), DOD, DHS, 

VA, NPS, BLM, Department of the Interior (DOI), the National Conference of State 

Historic Preservation Officers, and the National Trust for Historic Preservation, the 

work group developed and approved recommendations to improve the “historical status” 

field of the FRPP, which were submitted to GSA’s Office of Government-wide Policy 

and incorporated in the 2014 edition of the Data Dictionary. In addition, the ACHP 

executive director briefed the FRPC members on the role of the ACHP, historic property 

stewardship, and federal compliance responsibilities. The work group has identified 

additional areas on which it may advise the FRPC regarding historic asset data to 

improve its usefulness in agency planning and plans to continue this advisory relationship 

forged in 2014. 

Most agencies developed their Section 3 progress reports using agency-specific real 

property management systems in addition to FRPP data. For some agencies, like U.S. 

Customs and Border Protection (CBP), the reporting system used is new and was 

designed with an eye to improve upon the experiences of other agencies and to address 

the concerns of GAO in its several reports. Other agencies continue to use separate 

systems because the FRPP is designed to document buildings and structures but 

typically does not include data regarding archaeological sites, nor does it consistently 

collect data on historic districts and objects. BLM reports that generally archaeological 

sites will not be included in the FRPP unless they are improved for visitation with access, 

interpretation, adjunct buildings or structures, or other structural features. 

In addition, USPS reports that it had numerous errors between its internal electronic 

Facilities Management System and the National Register of Historic Places data on file 

with the NPS. In March 2014, USPS began reconciling this data such that it will be 

more useful in future Section 3 and other reporting. In general, the ACHP notes that 

the National Register files are difficult to reconcile with almost all agency real property 

databases for a variety of reasons, most notably:

» Federal real property databases typically document only buildings and structures, 

while the National Register includes historic buildings, structures, sites, objects, 

and districts.

32 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
CBP has made significant improvements 

in its identification and evaluation of 

historic properties since 2011. CBP’s 

efforts address both owned and 

leased facilities so that the agency has 

a full picture of its portfolio, regardless 

of ownership. In 2012, the Cultural 

Resources Integrated Organization System 

(CRIOS) was developed to provide CBP 

with a consolidated database to house 

and maintain all data regarding historic 

properties, including reports and eligibility 

determinations. The system was designed 

as an interim step toward inclusion of 

historic property data into CBP’s real 

property database, known as TRIRGA. 

The integration of the historic property 

data into the larger system was identified 

by CBP leadership as a priority project. 

Early integration and coordination began 

in October 2012 for the development of 

the application enhancement. In May 2014 

this effort was concluded and the Cultural 

Resources in TRIRGA (CRIT) function 

was fully added to the TRIRGA system. 

Upon the completion of this effort, the 

CRIOS system was stood down and is no 

longer used. 

CRIT was designed to address specifically 

how CBP manages both its real property 

and its historic resources. The system 

complies with Section 110 of the NHPA 

requirements for CBP to properly manage 

and maintain its historic properties as 

well as DHS Directive 017-01, “Historic 

Preservation in Asset Management and 

Operations,” which requires CBP to 

manage actively its historic properties and 

to manage its historic property data in an 

auditable format. 

Since the development of CRIOS and 

CRIT, CBP has obtained a much more 

accurate picture of the historic properties 

within its portfolio. The integration of the 

historic property data into the agency’s 

real property database addresses many 

of the data maintenance issues raised 

by GAO in its report, “Federal Real 

Property: Improved Data Needed to 

Strategically Manage Historic Buildings, 

Address Multiple Challenges” (2012). To 

reduce obstacles to providing accurate 

data, CBP only uses the historic status 

used by the FRPC, and the Real Property 

Administration Branch has transferred 

responsibility for the historic status section 

of the FRPC data to the Environmental 

and Energy Division, the division within 

CBP responsible for overseeing the 

agency’s compliance with NHPA and 

other historic preservation laws. This data 

is also maintained within TRIRGA and is 

automatically synchronized with CRIT.

CASE STUDY

Inventory Data 

Management

FEDERAL AGENCY

U.S. Customs and Border 

Protection (CBP)

LOCATION 

Nationwide

CREDIT: CBP

CBP maintains and operates historic border crossing facilities and U.S. Customs Houses, 

including the one in Mayaguez, Puerto Rico.

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 33
» Many federal real property databases record historic properties at the individual 

building and structure level, while the National Register “counts” historic districts as 

single historic properties which may contain many contributing buildings, structures, 

objects, and sites.

The NPS is unique in that it maintains an evaluated inventory of cultural landscapes 

having historical significance, in which the NPS has, or plans to acquire, a legal interest. 

NPS reports that at the end of FY 2014, the inventory contained approximately 700 

cultural landscapes that are eligible for or listed in the NRHP or those that are managed 

as a cultural resource because of legislation or park planning process decisions. About 

124 of these were added since September 2010.

NOTABLE INVENTORY STUDIES

Despite an overall decline in funding, in 2012 a number of agencies completed context 

studies and nominations to the NRHP for large landscape scale historic properties using 

American Recovery and Reinvestment Act (ARRA) funding:

» The U.S. Army Corps of Engineers (USACE) used ARRA funds to complete 

40 work orders for identification efforts totaling $20 million in 18 months. The 

contractors conducted archaeological survey, site evaluations, geo-archaeological 

assessments, condition assessments, Geographic Information System (GIS) data 

analysis and modeling, and curation. As a result, 76,000 acres were surveyed; 929 

sites were identified; 601 sites were revisited; 42 sites were tested for eligibility 

to the NRHP; 453 sites were determined eligible for the NRHP; 428 sites were 

determined not eligible for the NRHP; and 48 sites will require further evaluation 

to determine eligibility.

» BLM used ARRA funds, partnerships with trail associations, and consultants 

through the National Historic Trails Inventory Project to inventory more than 

247 linear miles along the Oregon, Mormon Pioneer, California, and Pony Express 

National Historic Trails. Archaeologists recorded 206 trail segments, 130 associated 

sites, and 64 isolated resources. BLM completed a visual setting inventory at various 

observation points along the corridors and provided a historic landscape integrity 

analysis at each point.

Other agencies used appropriations combined with partnerships to accomplish 

identification efforts. Since Hurricane Sandy struck the eastern coast of the U.S. in 

October 2012, shipwreck timbers and 150-year-old artifacts like shoes and bottles have 

been washing ashore in the Chincoteague National Wildlife Refuge in Virginia. The Fish 

and Wildlife Service (FWS) contracted an archaeologist and enlisted volunteers to tag 

the shipwreck timbers and track them as the ocean degraded and moved them over time. 

The team developed a new type of tag, based on those used to track marine mammals, to 

improve the success of the program.

In 2012, USPS collaborated with the National Conference of State Historic Preservation 

Officers and NPS to complete a nationwide historic context study for Postal Service 

buildings, 1940-1971. This context is helpful for the agency as it continues its efforts to 

dispose of unneeded properties to address its financial crises. 

Washington High School students from 

Washington Court House, Ohio, research 

unmarked veterans’ graves and partner with 

the National Cemetery Administration (VA) 

to obtain headstones.

CREDIT: PAUL LARUE

34 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
SECTION 110 AND SECTION 106

While Section 110 of the NHPA requires federal agencies to identify historic properties 

under their jurisdiction or control, the Act does not provide specific metrics by which 

to enforce compliance. Section 110 prescribes a proactive approach and is especially 

valuable for facility, regional, and national level real property decision making for the 

short and long terms. Section 106, on the other hand, requires an agency to identify 

historic properties in the area of potential effect for a program or project. It is reactive 

and designed to answer undertaking-specific data needs. Most agencies report they will 

continue in austere budget circumstances to rely primarily on the Section 106 process to 

inventory their historic properties on an as needed basis.

Further, while Section 110 of the NHPA requires federal agencies to nominate historic 

properties under their jurisdiction or control to the NRHP, many do not routinely set 

aside the resources to do this. Several agencies expressed the opinion that NRHP listing 

is unnecessary to achieve protection and a burden on resources. As an example, the 

Bureau of Reclamation (BOR) stated, “A ‘consensus’ determination of eligibility with a 

SHPO provides the same level of protection to a historic property as does listing, but 

requires far less time and expense to accomplish.” 

Even when inventory is completed as part of the Section 106 process, agencies have 

demonstrated that the scope of the inventory effort can be designed to maximize its 

usefulness after the immediate undertaking. In one example, the Walter Reed Army 

Medical Center in Washington, D.C., contracted USACE to survey the federal facility 

as part of the Section 106 process for the base closure in accordance with BRAC. For 

the first time in its history, the entire base was evaluated holistically, including the 

cultural and designed landscapes. The result of this comprehensive and collaborative 

historic property inventory process was the determination of eligibility for the Walter 

Reed Army Medical Center Historic District consisting of 35 contributing resources 

in the areas of healthcare, education, and defense. In addition, the base was found 

to be significant as a Civil War battlefield associated with the Battle of Fort Stevens, 

July 11–12, 1864. The inventory aided in the development of existing condition studies 

to be used for future development of the site, created source materials for public 

interpretation stipulated in the Section 106 agreement, and produced photographs 

made available to the public on Flickr. 

STEWARDSHIP AND AGENCY PLANNING

A number of agencies have reviewed and improved their historic preservation policies 

and procedures in this reporting cycle. Required by EO 13604, “Improving Federal 

Performance of Federal Permitting and Review of Infrastructure Projects,” (2012) land 

managing agencies that issue permits, licenses, and other approvals for transmission 

lines, alternative energy, transportation, or other infrastructure projects considered and 

implemented any needed clarifications of policy or procedures that would improve 

performance in the permitting process. 

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 35
In this reporting cycle, the most challenging issue for all agencies has been the integration 

of historic preservation values into agency real property planning. Nearly all agencies 

report historic buildings and structures in their ownership that are currently unoccupied, 

some mothballed, and others with deferred maintenance. Current initiatives to “Freeze 

the Footprint” and dispose of unneeded real estate assets are shining light on federal real 

property management and exposing these unused and often neglected historic properties 

as ripe for disposition decisions. 

AGENCY POLICIES AND PROCEDURES

In the reporting cycle, the ACHP, BLM, and DOI continued the Western Renewable 

Energy and Historic Preservation Workgroup established in July 2011. Workgroup 

discussions and EO 13604 led BLM to make policy and procedure changes published in:

» BLM Instruction Memorandum 2013-020, “Section 106 Compliance on Major 

Infrastructure Projects”

» Information Bulletin 2013-060, “Interim Guidance for Compliance with Section 

106 of the National Historic Preservation Act and Tribal Consultation for Major 

Infrastructure Projects”

» Information Bulletin 2014-055, “Interim Guidance, Tribal Consultation; Questions 

and Answers for Major Infrastructure Projects; Legal Parameters in the Section 106 

Tribal Consultation Process”

In October 2013, the Secretary of the Interior issued Order No. 3330, “Improving 

Mitigation Policies and Practices of the Department of the Interior,” which established a 

Department-wide mitigation strategy ensuring consistency and efficiency in the review 

and permitting of infrastructure development projects. Central to this strategy is (1) the 

use of a landscape-scale approach to identify and facilitate investment in key conservation 

priorities in a region, (2) early integration of mitigation considerations in project planning 

and design, (3) ensuring the durability of mitigation measures over time, (4) ensuring 

transparency and consistency in mitigation decisions, and (5) a focus on mitigation 

efforts that improve the resilience of the nation’s resources in the face of climate change. 

Accordingly, BLM reports it is implementing a “landscape scale” approach to its land 

management. With this approach, staff has the opportunity to identify critical heritage 

issues and areas prior to land use and project planning, to prioritize important resources 

for consideration and preservation; to identify and prioritize important questions; and to 

identify regional mitigation strategies to address direct, indirect, and cumulative impacts 

generated by major infrastructure projects. 

DOD also reviewed its permitting policies and procedures. The Department of Defense 

Retrospective Review Plan Report, July 8, 2013, stated that the regulations, “Application 

Guidelines for Archeological Research Permits on Ship and Aircraft Wrecks under 

the Jurisdiction of the Department of the Navy,” (32 CFR Part 767) are being updated. 

The rule establishes a single permitting process for members of the public wishing 

to engage in activities on Department of the Navy ship and aircraft wrecks. The 

rule also incorporates provisions for a special-use permit to be issued in the case of 

Mount St. Helens National Volcanic 

Monument on the Gifford Pinchot National 

Forest in Washington. In this report period, 

the U.S. Department of Agriculture began 

implementing its Final Sacred Sites Report, 

released in December 2012, by working 

more closely with tribal governments in the 

protection, respectful interpretation, and 

appropriate access to Indian sacred sites.

CREDIT: SHUTTERSTOCK

36 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
minimally intrusive operations such as sample collection or remotely-operated vehicle 

documentation of historic sites. In addition, the rule outlines penalties and enforcement 

procedures and provides an avenue for the public to access sites that are otherwise 

restricted from disturbance by the Sunken Military Craft Act (Title XIV of the FY 2005 

National Defense Authorization Act, 118 Stat. 2094). Such access will allow research 

that can bring to light new information about the nation’s maritime heritage and increase 

public knowledge of the U.S. Navy’s history and service.

CONSOLIDATION

GSA reports that in this reporting cycle a positive trend toward fewer new leases may 

indicate consolidation in federally owned buildings, from which vacancy-troubled legacy 

historic buildings could benefit. In addition, reduced property acquisition during the 

reporting cycle is another positive reflection of GSA efforts to reduce the footprint and 

make the most of available property, especially legacy historic buildings. As an example, 

the Department of State (DOS) needed to acquire space for its Security Training Center 

and decided to co-occupy Fort Pickett in Blackstone, Virginia, with the Virginia Army 

National Guard. Co-location is an exceptional fit and a welcome economic development 

for the rural area. GSA also reports five projects in 2014 to consolidate federal tenants in 

historic public buildings which will reduce reliance on leasing, shrink the federal footprint, 

and strengthen the Federal Buildings Fund:

» John A. Campbell U.S. Courthouse, Mobile, Alabama

» Lewis F. Powell Jr. U.S. Courthouse and Annex, Richmond, Virginia

» Frank E. Moss U.S. Courthouse, Salt Lake City, Utah

» Hubert Humphrey Federal Building, Washington, D.C.

» Mary E. Switzer Federal Building, Washington, D.C.

MASTER PLANNING

Ideally, federal agencies are making their decisions about how to consolidate office and 

warehouse space in the context of a master plan that includes an inventory of historic 

properties and consideration of the potential effects of consolidation efforts like 

mothballing, demolition, leasing, and disposal on historic properties through the Section 

106 process. 

Two agencies were recognized for their integration of historic preservation concerns 

in the Facilities Modernization Plan for the Patuxent Research Refuge, established 

in 1936. While the plan provided for the demolition of approximately 80 buildings, 

both historic and non-historic, through the Section 106 process, FWS and the U.S. 

Geological Survey (USGS) committed to public interpretation programs. Accessible 

at the newly completed National Wildlife Visitor Center, the video, exhibit, guided 

tours, and brochure tell the story of both the natural and cultural significance of the 

property and its development over time. In honoring the two federal agencies with 

the “Outstanding Stewardship of Historic Properties by a Government Agency” 

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 37
The AFRH is an independent federal 

agency that manages the nation’s oldest 

continuously operating retirement 

community for veterans of the armed 

forces, at least one-half of whose 

service was not active commissioned 

service. AFRH owns and manages two 

campuses–in Gulfport, Mississippi, and 

Washington, D.C.–with a mission to fulfill 

the nation’s commitment to veterans 

by providing a premier retirement 

community, exceptional residential care, 

and extensive support services. The 

Washington facility (AFRH-W) is a 272-

acre campus located in the northwest 

quadrant of the District of Columbia. 

The entirety of the AFRH-W campus is 

an eligible and listed historic district in 

the NRHP and the District of Columbia 

Inventory of Historic Sites. Within the 

campus are also the United States 

Soldiers’ and Airmen’s Home NHL and 

the President Lincoln’s Cottage and 

Soldiers’ Home National Monument.

AFRH is a financially independent 

agency, does not receive appropriations 

from Congress, and is sustained by a 

permanent trust fund (Trust Fund) that 

was established in the late 19th century. 

As the character of military action 

continues to evolve, future residents at 

AFRH will have different medical and 

accessibility requirements than past 

and current residents. Therefore, AFRH 

must modernize its facilities to address 

the changing needs and challenges of 

veterans from recent conflicts. AFRH 

must also provide its residents with 

facilities designed to reflect the latest 

standards and practices in senior 

housing and healthcare. As AFRH’s 

infrastructure continues to age, rising 

costs of maintenance and operation 

of historic buildings competes with 

the agency’s responsibility to provide 

services to residents. In response, the 

AFRH has made comprehensive efforts 

to plan for preservation outcomes while 

supporting its mission, which could serve 

as a model for all property managing 

agencies responsible for the stewardship 

of “campus like” historic districts.

The 2008 AFRH-W Master Plan identified 

historic buildings and structures available 

for transfer, lease, or sale. Areas for 

lease and development were identified 

based on the agency’s goals to increase 

operational and programmatic efficiency 

by consolidating all current residential 

operations in the campus core and 

eliminating duplicative functions that 

are currently distributed throughout 

the campus. As of FY 2014, AFRH is 

prioritizing the leasing of vacant space 

within historic buildings. AFRH has 

successfully leased buildings and spaces to 

individuals, government entities, schools, 

and non-profit organizations. One of 

the most successful examples is the 

Cooperative Agreement AFRH maintains 

with the National Trust for Historic 

Preservation, providing the opportunity 

for some 30,000 members of the public 

to visit the Lincoln Cottage and Visitor 

Center (Building 10—Administration 

Building) each year.

Concurrent with the development of 

its Master Plan, the agency adopted the 

AFRH-W Historic Preservation Plan as 

its guiding document for compliance 

with the NHPA and for the protection 

of the AFRH-W Historic District. The 

preservation plan establishes policies, 

actions, and procedures that ensure 

Charles Magnus c. 1863 lithograph of the Soldiers’ Home, Washington, D.C., now known as 

the Armed Forces Retirement Home

CASE STUDY

Facility Planning 

For Preservation 

Outcomes

FEDERAL AGENCY

U.S. Armed Forces Retirement 

Home (AFRH)

LOCATION 

District of Columbia

CREDIT: LIBRARY OF CONGRESS

38 | CHAPTER 3— CHAPTER 1—CURRENT STATE OF FEDERAL STEWARDSHIP INTRODUCTION AND BACKGROUND | 38
preservation is integrated into the 

agency’s daily operations.

AFRH monitors its historic resources 

through the implementation of 

the agency’s standard operating 

procedures, specifically those stipulated 

in the AFRH-W Historic Preservation 

Maintenance Program. Facilities 

management contractors and the Cultural 

Resource Manager complete specified 

daily, monthly, and annual monitoring 

actions. The maintenance plan provides 

consistent guidelines for maintenance 

and monitoring, allowing coordination of 

data gathered from multiple sources. In 

addition to the monitoring actions, this 

program outlines standard operating 

procedures for cyclical, emergency, and 

daily maintenance activities.

In FY 2011, AFRH drafted a 10-year 

Capital Improvement Plan (CIP) for both 

campuses based on the 2008 Master 

Plan. The CIP captures all anticipated 

capital improvements through FY 2021, 

and proposes each project as part of a 

broader agency program or goal. Historic 

preservation and stabilization is one of 

the five agency programs supported 

and implemented through these capital 

improvements, accounting for 21 percent 

of proposed projects for AFRH-W. The 

Cultural Resources Manager participated 

in all phases of the preparation of the 

CIP. Thus the stewardship of historic 

properties is an integral part of the 10-

year plan as created and implemented.

In 2011 and 2012, as part of the recovery 

effort from the August 2011 earthquake 

that struck the mid-Atlantic region, AFRH 

coordinated with contractors to stabilize 

immediately the Sherman Building, one 

of the most iconic buildings on the 

AFRH-W campus. Over a period of 10 

months, more than 3,000 exterior stones 

were reconstructed on the Sherman 

Building as structural, plaster, ornamental, 

and roof repairs were completed. A 

custom structural steel frame was 

constructed within the previously 

unreinforced clock tower; more than 20 

courses of marble were deconstructed 

and reconstructed to accommodate the 

frame. The extensive deconstruction of 

the clock tower not only allowed for a 

long-term repair of the building but also 

taught contractors and the agency about 

the original construction methods and 

practices. In May 2014, the AFRH was 

recognized for its efforts by the District 

of Columbia State Historic Preservation 

Officer’s Award for Excellence in 

Preservation.

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 39
2013 Maryland Preservation Award, the Maryland State Historic Preservation 

Officer praised FWS and USGS for demonstrating outstanding stewardship by 

enthusiastically embracing the opportunity to expand their mission beyond natural 

resource interests. As a result of their efforts, visitors to the Refuge are now exposed to 

the cultural values of the property and can engage in exploring and understanding the 

site’s history and development over time.

In another example, Fort Hunter Liggett in California contracted USACE to prepare a 

maintenance manual for “The Hacienda,” a historic property listed in the NRHP. The 

maintenance manual:

» Presents preservation planning concepts in a jargon-free format geared to nonpreservation professionals at the installation level;

» Is linked to the Internet to allow easy updates and accessibility – general 

photographs, maintenance issues, and identification of intrusive design issues 

are hyperlinked in the manual and accessible at https://www.flickr.com/photos/

fhlhacienda/sets/; 

» Provides a clear explanation of what is important and why and how to keep it that 

way; 

» Recognizes the Army’s role in the history of the structure in addition to that of 

William Randolph Hearst; 

» Integrates cyclical maintenance and historic preservation; and

» Recommends preservation priorities for future rehabilitation of character-defining 

features that will enhance visitor experience.

LEASING AND OTHER COST SHARING APPROACHES

Many agencies are exploring opportunities to outlease historic buildings and structures 

to achieve preservation goals, minimize federal maintenance costs, and, in some cases, 

generate federal revenue. For example, VA has used its authority (38 U.S.C. §§ 8161—

8169) for EULs whereby VA-owned property may be leased for use by a non-federal 

entity to provide veterans’ services. In the past, the scope of eligible veterans’ services was 

broad, but in this reporting cycle, Congress limited new EULs to those providing for 

transitional housing for homeless veterans. 

In 2012, the National Trust for Historic Preservation honored The Pioneer Group, 

the lessee of Building 19 at the Leavenworth VA Medical Center in Kansas. The 

combination of a National Historic Landmark, a group of grassroots preservationists, 

and an innovative public-private partnership made the newly restored Leavenworth 

Building 19 possible. When officials proposed demolition of the abandoned 1886 dining 

hall, concerned citizens formed Veterans Administration Leavenworth Opportunity 

for Reuse or “VALOR.” VALOR and developer, The Pioneer Group, worked tirelessly 

with VA to find alternatives to demolition. With the investment of private funds, 

historic features were preserved, insensitive alterations were removed, and modern office 

40 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
amenities were added. Leavenworth Building 19 now houses a new VA medical records 

office that brought 400 jobs to town.

The U.S. Coast Guard (USCG) also reports that it has successfully outleased historic 

lighthouses to responsible parties that assume management duties, undertake restoration 

and maintenance, and make the properties available for public access. 

During this reporting cycle, GSA reports using the leasing authority of Section 111 of 

the NHPA to great effect. The most significant success was the 60-year ground lease 

of the 1899 Old Post Office in Washington, D.C., to the Trump Organization. This 

long-term lease permits the utilization of the federal historic tax credit to leverage the 

private capital necessary to rehabilitate the building as a 270-room luxury hotel while 

maintaining its exceptional historic attributes and ensuring no adverse effect to this 

city focal point and symbol of the preservation movement. Visitors will enjoy access 

to restaurants in the nine-story historic atrium, invigorated sidewalks with open air 

cafes, and re-opened access to the 315-foot bell tower offering panoramic views of the 

nation’s capital.

GSA reports that the allocation of Section 111 lease revenues for the benefit of 

historic properties in its portfolio is an important aspect of this authority. Although 

modest compared to GSA’s other capital investment programs, strategically invested 

outlease revenue makes an important difference for many historic buildings unable 

to compete for prospectus level funding. Combined with other funding sources, such 

as private investment and historic tax credits, Section 111 leases can fill critical gaps, 

enabling GSA to address historic material repairs and seize opportunities to meet 

federal stewardship goals. In FY 2013, GSA conducted a review which resulted in the 

recoding of $1.8 million in outlease revenue, increasing the funds in the program for 

the year by 34 percent. 

In 2013, the National Trust for Historic Preservation published “Historic Leasing in the 

National Park System: Preserving History through Effective Partnerships.” The report 

identifies some of the barriers that are currently preventing greater use of the Section 

111 leasing authority and other partnership tools, describes examples of the successful 

use of long-term leases to facilitate private investment with historic tax credits within 

NPS units, and provides recommendations for moving forward more effectively. NPS 

reports it continues to lease historic properties in accordance with its procedures at 36 

C.F.R. Part 18, as authorized both by Section 111 of the NHPA and Section 802 of 

the National Parks Omnibus Management Act of 1998 (16 U.S.C. § 1a-2(k)). These 

procedures are supported by “Historic Property Leases and Cooperative Agreements” 

(Section 5.3.3), Management Policies, 2006, and Director’s Order 38: “Real Property 

Leasing.” Expanded use of historic leasing could help abate the multi-billion dollar NPS 

maintenance backlog for under-utilized and unused buildings and structures.

One of the approaches FS has developed to save underutilized historic buildings is 

its Cabin Rental Program, providing overnight recreation accommodations to the 

public for a fee. Cabins, fire lookouts, and small lodges have been restored with period 

furniture to offer an affordable heritage tourism experience for the public. While this 

has been a successful, cost sustaining endeavor, growth is impeded by limited resources 

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 41
and funding. As of 2014, there were 445 buildings and structures in the Cabin Rental 

Program. An analysis of the inventory indicates a potential of 4,000 to 6,000 historic 

buildings and structures that could be converted to overnight accommodations. FS 

reports it is considering policy changes for private use of historic buildings and 

structures to encourage private investment, but establishing the authority to do so may 

take several years.

In this reporting cycle, VA and FS requested the ACHP to assist them in considering 

the use of Section 111 leasing authority. As recommended in the 2012 Report to the 

President, the ACHP has and will continue to consult with VA, FS, GSA, NPS, and 

National Trust for Historic Preservation on the effective use of Section 111 to ensure 

preservation of historic properties.

DEMOLITION AND DISPOSAL

In accordance with the “Freeze the Footprint” policy, any growth in total office or 

warehouse space must be offset by a corresponding decrease through declaration of 

excess, disposal, or closed/realigned as part of a DOD BRAC process. Most importantly, 

OMB policy states that an agency may not use as an offset property that the agency has 

“mothballed” or those subject to EULs and outleases. So while reuse by the controlling 

agency or transferring the property to another federal agency may address both the 

footprint and historic preservation policies, a preservation outcome such as an outlease–

EUL, Section 111, or other authority–is often in conflict with the footprint policy. 

Even when outleases present an opportunity to leverage non-federal investment in the 

maintenance and continued use of buildings and structures imbedded in federal facilities 

or otherwise unsuitable for disposal, such outleases may not be considered as an offset. 

As a result, this policy has led agencies that believe new buildings or structures may be 

needed now or in the future to pursue demolition and disposal, regardless of whether 

historic properties may be adversely affected. While the “Freeze the Footprint” policy 

seems on its face to encourage reuse, it has actually had the opposite effect, encouraging 

the demolition of historic buildings and structures imbedded in federal facilities.

For example, CBP reports significant challenges in its continued use of its historic 

facilities. As the agency mission and law enforcement standards and methods have 

changed, the space and layout requirements for facilities have also changed. In addition, 

deferred maintenance has increased the life-cycle costs for older facilities. Expansion 

in place may not be feasible when a port of entry is constrained by the border and 

surrounding urban development. In such cases, CBP is apt to choose new construction 

and demolish, excess, or dispose of a historic facility for the footprint offset.

In an unusual example, USGS is combining a demolition and new construction project 

with a historic preservation outcome. It is currently demolishing a “rabbit-warren” of 

building additions to the historic U.S. Lifesaving Service Station at Hammond Bay 

Biological Station in Millersburg, Michigan. The Lifesaving Service Station will be 

restored to its historic appearance. Meanwhile, a new laboratory is being built on the site 

to centralize and modernize the lab functions with a zero net gain in square footage. 

42 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
In this reporting cycle, agencies have experienced both challenges and success in the 

disposal of historic properties. GSA issued new agency guidance on disposals in 

2012. The disposal of historic properties requires market analysis to determine if 

conveyance with preservation restrictions is feasible. As a result, sometimes disposal of 

a historic property is a two-step process with a preliminary solicitation to identify the 

preservation conditions that the market may bear. GSA and USCG also reported on 

the success of the Federal Property and Administrative Services Act of 1949 and the 

National Historic Lighthouse Preservation Act disposal processes for lighthouses. In 

the 14 years since its establishment, GSA has successfully conveyed more than 100 

lighthouses with preservation protections through the program. USCG noted this 

program typically takes five or more years to accomplish each transfer of a historic 

lighthouse, whereas a typical public auction of a non-historic lighthouse or other 

property can be completed in three months. However, according to GSA, the time 

to complete a lighthouse conveyance is affected more by climate and seasonal timing 

than its historic status and the corresponding disposal authority. GSA’s data indicates 

that conveyances under both authorities for historic and non-historic lighthouses are 

similar, usually within 12–24 months.

The Indian Health Service (IHS) noted that the majority of its historic properties are 

located on Indian trust lands, such that excess property is offered to the Indian tribe. It 

often takes five or more years to determine the disposition of any buildings or structures, 

and, in the meantime, they are vacant and not maintained. Similarly, BIA reports that 

excess properties under its control are located on Indian reservations and so cannot be 

transferred to any other organizations or entities other than the tribes. If tribes do not 

desire the buildings, the only option is demolition. Even in cases where tribes request 

transfer of buildings, costs associated with repairs and the remediation of hazardous 

materials often prohibit tribes from accepting them.

Similarly, BIA reports that, beginning in 2002, a new school construction program was 

initiated on many reservations in an effort to address deficiencies in the educational 

facilities. The ARRA also infused additional funds into new school construction. This 

resulted in the abandonment of some older school buildings and related structures which 

were no longer needed, many of which are considered historic. Since the re-use of these 

buildings is limited by the cost of repairs and hazardous materials remediation and 

security considerations, many of these buildings have been identified for demolition. 

Since 2008, USPS has increased its rate of disposals, in part to generate revenue and 

stem maintenance investments that will help address the self-supporting agency’s 

financial crisis. The agency reports that leasing is not feasible, but that often it is able to 

transfer historic properties out of federal ownership with covenants it believes ensure longterm historic preservation, and cites examples in California, Connecticut, Illinois, Kansas, 

Michigan, New Jersey, New York, and Pennsylvania in the reporting period. The ACHP 

and other stakeholders have found that the USPS covenants are often inadequate to 

ensure long-term preservation. The USPS has been challenged to manage the Section 106 

process for these undertakings and in two locations, litigation has been filed challenging 

the agency’s compliance with Section 106. (See the Case Study in Chapter 2)

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 43
A few agencies have acquired lands during the reporting cycle. The Tennessee Valley 

Authority (TVA) reported that it acquired 1,253 acres to expand the Cumberland Fossil 

Plant reservation. After acquisition, it discovered the new lands included a property listed 

in the NRHP, Hollister House. The agency subsequently determined that the historic 

house and its 4.7 acre parcel were excess to its needs, and now it proposes to dispose 

of the property with a historic preservation covenant. TVA reports that the agency has 

learned from this experience and improved staff awareness of historic preservation issues 

and directed consideration of available historic preservation data prior to acquisition.

CLIMATE CHANGE

While some agencies did not identify climate change as a significant issue or program, 

others noted that their agency has a Climate Change Adaption Plan and/or is concerned 

with the viability of its facilities in vulnerable locations. For example, the Department of 

Health and Human Services (HHS) reports that, while the current 2012 HHS Climate 

Change Adaption Plan does not specifically address impacts to historic properties, it is 

being updated. A section concerning historic properties is expected to be added to the plan.

The BOR reports that it completed a Section 106 review and executed a Programmatic 

Agreement with Tahoe National Forest, USACE, and the California SHPO regarding 

the Stampede Dam Safety of Dams Modifications Project. BOR will increase the height 

of Stampede Dam by 11.5 feet to accommodate 110 percent of the Probable Maximum 

Precipitation, so the agreement will resolve the adverse effects to more than a dozen 

historic properties behind the dam that would be inundated if the reservoir were filled 

to capacity.

FS reports it has identified high elevation archaeological sites, formerly protected by snow 

and ice fields, among its most vulnerable historic properties to climate change. Fragile 

artifacts such as baskets and other organic items are well preserved when they remain in a 

dry case or frozen under deep snow and ice. The melting of snow and ice fields caused by 

climate change now exposes these artifacts which begin to decay rapidly if not recovered 

by archaeologists. FS has partnered with several universities to survey and record exposed 

and vulnerable sites. FS reports that, while exposure of artifacts has provided new 

insights into human behavior at high altitudes, the rate of melting will result in more loss 

of information than gain.

In this reporting cycle, NPS reported the most robust comprehensive planning effort 

regarding protecting historic properties from the effects of climate change. In 2011, the 

agency implemented a GIS project using existing inventory data to identify historic 

properties vulnerable to sea level rise and prioritize them for documentation by the 

Historic American Building Survey/ Historic American Engineering Record/ Historic 

American Landscape Survey based on their risk assessment. In October 2012, many 

NPS parks in the Northeast Region, notably Ellis Island and the Statue of Liberty, were 

devastated by Hurricane Sandy, necessitating a mobilized response. These efforts were 

followed by a Director’s Memorandum, “Climate Change and Stewardship of Cultural 

Resources” (2014), requiring all identified cultural resources to be evaluated in terms 

of their vulnerability and significance so that management decisions are directed to 

resources that are both significant and most at risk. In addition, NPS provides leadership 

44 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
in the historic preservation community on preparing for the impacts of climate change. 

In 2014, the agency hosted more than 70 federal, state, local, non-profit, and university 

leaders at its “Preserving Coastal Heritage Work Session” to draft a decision framework 

for managing vulnerable cultural resources impacted by climate change.

MANAGING ASSETS

Federal agencies continue to manage historic properties in their ownership by adaptively 

reusing them, rehabilitating and restoring them, and protecting them. Maintaining 

historic buildings and structures in “good” condition remains a challenge for federal 

agencies, even as they define “good” in accordance with their own standards. Agencies 

report that, according to their respective real estate management systems, the following 

proportions of the historic properties in their ownership are in “good” condition:

» BIA: 36 percent of its 259 historic properties (with various contributing resources)

» BLM: 52 percent of its 421 historic buildings and structures

» CBP: “vast majority” and “no properties in a state of collapse or with structural failure”

» NASA: 100 percent of its 261 historic properties (with various contributing 

resources)

» Centers for Disease Control (CDC): 100 percent of its two historic properties (with 

various contributing resources)

» Food and Drug Administration (FDA): None (historic property maintained in “fair” 

condition)

NPS reported the condition of its historic properties based on comprehensive condition 

assessments on a five-year revolving cycle in terms of the calculated Facilities Condition 

Index (mathematically, the deferred maintenance value divided by the number of 

properties). In this scale, an Index of 0.000 is a property in “perfect” condition, while 

a value equal to or greater than 1.000 indicates a property for which the cost of 

maintenance equals or exceeds its replacement value. NPS reports that 11,935 of its 

historic buildings, structures, and cultural landscapes require $4.6 billion in deferred 

maintenance resulting in an average Index of 0.052. Adaptive reuse, rehabilitation, and 

restoration of historic buildings and structures may seem similar to a lay person, but they 

typically differ by degrees of change to the characteristics qualifying the historic property 

for the National Register. But all three approaches have successfully accomplished the 

goal of preserving federal historic properties. 

HIGHLY TECHNICAL HISTORIC PROPERTIES

Federal agencies are often challenged to continue to use and adaptively reuse historic 

buildings and structures associated with highly technical systems and programs. All 

of the agencies with historic properties significant for their association with medical 

care and research–VA, IHS, AFRH, and National Institutes of Health (NIH)–report 

challenges adapting those properties for modern medical care and research activities. 

NIH reports that the nature of scientific research has changed over the seven decades of 

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 45
its Bethesda, Maryland, campus’ history, and it is often not feasible to adapt insufficient 

floor plate areas, column spacing, or ceiling heights for current mechanical systems. IHS 

reports that upgrading, renovating, and maintaining historic buildings are not always 

the most effective or efficient use of funds, particularly with respect to energy efficiency, 

operational effectiveness, and maintainability. AFRH has similar concerns, but, through 

the development and implementation of a facility master plan that considers historic 

preservation stewardship, the agency has consolidated its footprint in the historic north 

end of the campus. Needs for “modern” space were accommodated in the demolition of 

the 1950s Scott Building, a non-contributing building in the historic district, and the 

construction of a new Scott Building. The LEED Gold certified new building opened in 

2013 is 52 percent smaller and 30 percent more energy- and water-efficient per square 

foot than the old building. In addition to its “green design,” it is more sensitive to and 

compatible with the design of the historic district.

The Federal Aviation Administration (FAA) faces similar challenges in managing 

the numerous communications, navigation, and surveillance systems constituting the 

National Airspace System (NAS). This highly technical “system of systems” is unique to 

FAA, would not be of practical use to other entities, or could endanger NAS integrity if 

used for other purposes. The locations of its buildings and structures, often embedded 

in secure airport facilities, do not lend themselves to use by others. As a result, FAA has 

rarely adaptively reused or leased such properties. Generally, they are demolished when 

determined excess.

NASA also reports that the “Freeze the Footprint” policy presents a major challenge, and 

NASA is actively working to “Reduce the Footprint,” which routinely means demolition 

of older buildings and structures that do not meet current mission needs. Agency historic 

preservation staff has already seen an increase in the number of proposals to demolish 

historic structures and pressure to expedite the review of such proposals. This push to 

do more with less will inevitably impact additional historic properties, and even historic 

districts, as more mothballed and unused structures become ripe for disposition decisions. 

Even in this environment, NASA has been able to reuse historic properties successfully. 

Current agency policy regarding Facilities Project Requirements (NPR 8820.2G) 

specifically requires that a facility project manager must develop an adaptive reuse 

feasibility report, in conjunction with the historic preservation officer, if a building is 

eligible for the NRHP and planned for modification or demolition. Some of the highprofile successes during this reporting cycle:

» SpaceX will lease Historic Pad 39A at Kennedy Space Center in Florida for its 

commercial space program use. SpaceX will maintain the historic structure. This 

lease is part of the retirement of the Space Shuttle program, in which NASA 

transferred the Space Shuttle Orbiters for public viewing and interpretation to 

museums and visitor centers in Florida, California, New York, and Washington, 

D.C./Virginia. NASA also transferred the Shuttle Carrier Aircraft to the Johnson 

Space Center visitor center for public viewing and interpretation. NASA re-used the 

The renovation and reopening of the historic 

Harbor Control Tower at Joint Base Pearl 

Harbor-Hickam was celebrated with a 

traditional Hawaiian blessing ceremony in 2014. 

The historic structure is a water tank and 

signal tower located near the Pearl Harbor 

Naval Shipyard that survived the attack on 

December 7, 1941. CREDIT: NAVY

46 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
Shuttle Avionic Integration Laboratory for heritage tourism activities at the Johnson 

Space Center in Texas. (See the Case Study in Chapter 1)

» The Air Force took control of the Space Transportation System Program building in 

Palmdale, California, and will re-use it.

» NASA has re-purposed the gantry system, an NHL, at Langley Research Center in 

Virginia to operate a new Hydro Impact Basin for simulating Orion (America’s new 

spacecraft for human exploration) splash down testing.

» NASA modified Test Stand B-2, an NHL, at Stennis Space Center in Mississippi 

for reuse during testing of the Space Launch System.

» NASA leased Hanger One, a historic former Navy dirigible hangar, at Moffett 

Federal Airfield in California to Google, Inc. for rehabilitation and continued use as 

a hangar.

REHABILITATION FOR IMPROVED SUSTAINABILITY

In this reporting cycle, federal agencies emphasized successes in rehabilitating historic 

properties for continued use while also meeting energy efficiency and sustainability 

or “green design” goals set by EO 13514. One hallmark of highly green design is LEED 

certification by the U.S. Green Building Council. There are four levels of certification 

(from least to most green): Certified, Silver, Gold, and Platinum. While LEED 

certification is not required for federal buildings to meet the goals of EO 13514, 

some rehabilitation projects of historic buildings do achieve this hallmark. Some of 

the green planning design projects involving historic properties reported by agencies 

include the following:

» NIH used ARRA funds to renovate Building 3 in the Historic Core District in 

Bethesda, Maryland. Originally, the Public Health Methods and Animal Unit 

Building, it was adaptively reused as offices for the nearby Clinical Research Center 

while restoring the Neo-Georgian brick façade, windows, and slate roof. The project 

is LEED Certified.

» Beginning in 2002, FS rehabilitated its International Institute for Tropical 

Forestry in San Juan, Puerto Rico, melding energy efficiency, water conservation, 

and historic preservation. The project is LEED Gold certified. In May 2014, the 

Institute celebrated its 75th anniversary with the Spanish Colonial style building 

proudly displayed as its icon, symbolizing how natural resource conservation, 

environmental protection, and historic preservation are all part of an ethic 

embracing sustainability.

» In November 2011, the Department of the Treasury rehabilitated the Treasury 

Building in Washington, D.C. By improving the building systems to address water 

efficiency, reduce energy, and indoor environmental quality improvement, the 

Department achieved LEED Gold certification while not affecting the qualifying 

characteristics of the NHL. 

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 47
» The NPS’ National Center for Preservation Technology and Training (NCPTT) 

worked with BAC/Architecture + Planning, PLLC and Apollo BBC to undertake 

an “ecocharrette” on the National Register-listed Lee H. Nelson Hall, the Center’s 

headquarters in Louisiana. The ecocharrette included an energy audit of the building 

and led to the development of a sustainability management plan, which can be used 

as a model for other existing and historic buildings. (http://ncptt.nps.gov/blog/

sustainability-management-plan-for-lee-h-nelson-hall-2014-03/)

GSA, as a federal agency responsible for a large portfolio of historic federal buildings, has 

addressed the challenge of balancing historic preservation and green design at the highest 

policy level. GSA’s Public Buildings Commissioner, in his message preceding the Section 

3 progress report, writes:

“Since its founding 65 years ago, GSA has proven that the greenest building is the 

one already built. Reusing buildings and extending their service life creates a more 

sustainable federal government. Through innovative design, these buildings are 

modern, efficient, and inspiring workplaces that serve the missions of our client 

agency partners and the communities where the government does business.”

In this reporting cycle, GSA provided several outstanding examples of historic federal 

buildings rehabilitated to meet the highest green standards, including the following:

» The Hipolito F. Garcia Federal Building and U.S. Courthouse in San Antonio, Texas, 

earned GSA its first LEED Platinum certification. 

» The Wayne N. Aspinall Federal Building and U.S. Courthouse in Grand Junction, 

Colorado, is the agency’s first net-zero energy building. 

Other agencies reported smaller scale green design projects improving historic properties. 

In one such example, the U.S. Marine Corps installed photovoltaic panels at the Home of 

the Commandants, an NHL at the Marine Corps Barracks in the District of Columbia.

OTHER HISTORIC PROPERTY MANAGEMENT

While most federal agencies struggle to fund required and needed inventories of 

historic properties, a few are able to fund studies with value across federal agencies. The 

Albuquerque District in New Mexico of USACE reported on two such studies:

» In the Cochiti Deviation Artifact Movement Study, USACE seeks to understand 

better the direct impacts of periodic inundation and individual water deviations 

on artifact scatters, while also assessing the cumulative impacts of multiple events 

over time. During the five-year study, completed in 2013, Corps archaeologists 

observed the movement of metal washers of various sizes placed in the field to 

simulate prehistoric artifacts. As water levels fluctuated, naturally and from Corps 

actions, artifact locations were monitored and data was recorded about horizontal 

and vertical movement. The results of this study will provide a valuable baseline set 

of data useful for resource managers in the future, with specific focus on the effects 

of erosion, deposition, and spatial displacement of surface artifacts in periodically 

inundated environmental zones. 

48 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
In two recent rehabilitation projects, GSA 

was able to achieve the highest standards 

in sustainability and energy efficiency 

while also preserving historic federal 

buildings. These benchmark sustainability 

and historic preservation projects 

also contribute to downtown historic 

preservation efforts in their respective 

cities by maintaining the federal presence 

and the foot traffic of federal employees 

and users of federal services.

At the Hipolito F. Garcia Federal 

Building and U.S. Courthouse in San 

Antonio, Texas, GSA seized opportunities 

to restore significant spaces while making 

the most of the legacy building’s historic 

features and sustainability potential. 

The building is an important landmark 

and symbol of continued federal presence 

in the downtown. Situated across from 

the historic Alamo, the building holds a 

prominent position in Alamo Plaza, one 

of the city’s three major plazas. The 

building was a product of the Federal 

Public Works programs enacted to 

relieve widespread unemployment during 

the Great Depression of the 1930s. A 

skillful example of Beaux-Arts classicism, 

the U.S. Post Office and Courthouse is 

indicative of the federal government’s 

goal of expressing democratic ideals 

through classically derived architecture 

featuring grand scale, symmetry, and 

refined details. The U.S. Post Office and 

Courthouse is located in the Alamo Plaza 

Historic District. In 2000, the building was 

individually listed in the NRHP. 

A green roof, photovoltaics to fuel the 

building’s hot water, window and HVAC 

improvements, and smart building systems 

that respond to changing daylight and 

temperature conditions earned the 

project GSA’s first LEED Platinum rating, 

with no adverse effects on the building’s 

architecturally significant qualities. The 

project included an educational display 

on the history and architecture of the 

building, as well as its new sustainability 

features, encouraging agency tenants to 

conserve energy. 

Geothermal heating and cooling facilitated 

by the City’s granting of an alley easement, 

increased insulation, highly efficient 

lighting, 385 rooftop photovoltaic solar 

panels, and state-of-the-art building 

controls transformed the 1918 Wayne 

N. Aspinall Federal Building and 

U.S. Courthouse in Grand Junction, 

Colorado, into GSA’s first target net-zero 

site. Through iterative refinement of the 

solar array design, the project maintained 

the historic appearance of the building’s 

neoclassical façade while earning GSA’s 

second LEED Platinum rating. 

The historic Wayne N. Aspinall Federal Building and U.S. Courthouse in Grand Junction, 

Colorado, was rehabilitated, certified LEED Platinum, and is GSA’s first target net-zero site.

CASE STUDY

Historic Federal 

Buildings Go 

Platinum and 

Net-Zero

FEDERAL AGENCY

U.S. General Services 

Administration (GSA)

LOCATION 

Texas and Colorado

CREDIT: CAROL M. HIGHSMITH PHOTOGRAPHY, INC./GSA

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 49
Interior of Wayne N. Aspinall Federal Building and U.S. Courthouse, Grand Junction, Colorado

CREDIT: CAROL M. HIGHSMITH PHOTOGRAPHY, INC./GSA

The Aspinall Federal Building and 

Courthouse is architecturally significant 

as an important example of an Italian 

Renaissance Revival style government 

building designed by Supervising Architect 

of the Treasury James Wetmore in 1918 

with a significant addition in 1940 by 

Wetmore’s successor, Louis A. Simon. In 

addition, it is historically significant because 

of its association with an important U.S. 

congressional leader, Wayne N. Aspinall.

The project also restored character 

defining spaces and features that had been 

compromised over the building’s 96-yearlife. The main lobby—which had been 

reduced to a small entry vestibule—has 

been restored to its original grandeur, 

exposing original arched windows, 

decorative column capitals, a marblebordered terrazzo floor, and a threestory-high curved stair that had been 

hidden behind a wall. GSA also restored 

the building’s historic limestone and brick 

façades and ornamental metals, based on 

historic documentation.

50 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
» In the five-year Cerrito Recreation Area Site Protection Measure Study, USACE 

aims to assess the impact of increasing recreational access to an archaeological site 

and to empirically evaluate the effectiveness of specific site protection techniques in 

minimizing, or even decreasing those impacts to a site located in an intensively used, 

public recreation area.

A few agencies have also been able to accomplish restoration or reconstruction projects to 

benefit historic properties. For example:

» Arlington National Cemetery completed the first phase to restore two historic gates. 

Constructed in 1879 of salvaged pieces of the demolished north portico of the War 

Department Building (1812-1820), the Ord-Weitzel and Sheridan Gates stood for 

nearly 100 years as points of entry into the cemetery. The gates were constructed of 

blocks from the same Aquia sandstone quarries used to build the White House. In 

1971 when the cemetery expanded into Fort Myer, roads were widened and the gates 

were dismantled. Column sections, bases, entablatures, and urn caps were relocated 

to a forested area where they remained outdoors for more than four decades. In 

2012, the components were inventoried and moved to a staging site for analysis. 

The cemetery contracted the Technical Center of Expertise for the Preservation of 

Historic Structures and Buildings, Seattle District of USACE for forensic testing of 

the stone to determine damage and level of needed repair, and developed alternatives 

for restoration and reconstruction. In the project’s next stage, the components will 

be cleaned and repaired, missing features carved of new stone, and plans drawn for 

reinstallation of the gates.

» The California Department of Transportation, congressionally delegated for the 

Federal Highway Administration (FHWA), and VA completed the restoration of 

the historic fence and gates of the San Francisco National Cemetery in California. 

Necessitated by improvements to Doyle Avenue, the project included the 

reconstruction of a medallion missing from the gates.

CONTRIBUTING TO THE ECONOMY

Several federal policies encourage federal agencies to maintain or select sites for their 

facilities in central cities and rural town centers to strengthen the vitality and livability 

of the communities in which federal facilities are located. Further, agencies should place 

emphasis on examining the reuse potential of historic buildings and locating appropriate 

new buildings in historic districts. This reuse makes the most efficient use of already 

constructed buildings, supports preservation of historically significant structures, and 

promotes local economic development (See EO 12072, “Federal Space Management,” 

1978; EO 13514; and Department of Transportation, “Implementing InstructionsSustainable Locations for Federal Facilities,” 2011). While the ACHP’s experience 

with the various federal agencies demonstrates that they accept these principles, the 

progress reports submitted did not articulate the local economic benefits of rehabilitating, 

adaptively reusing, or consolidating federal leases in a historic building. 

Some agencies, like NPS, FS, and BLM include heritage tourism in their mission. These 

agencies routinely balance heritage tourism goals with other agency missions in the 

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 51
management of their existing, and, in some cases, expanding properties. The FY 2015 

National Defense Authorization Act, enacted in December 2014, includes a number 

of expansions to federal property. For instance, several new national parks will be 

created, including the Blackstone River Valley National Historical Park (Rhode Island), 

the Harriet Tubman National Historical Parks (New York and Maryland); and the 

Manhattan Project National Historical Park (New Mexico, Tennessee, and Washington).

On the other hand, other agencies find it difficult to connect historic preservation 

efforts at their facilities with local economic opportunities. The DOD comments are a 

representative type of response explaining how federal property access limitations present 

challenges to heritage tourism and economic development:

DOD limits access to installations based on security concerns, although there 

are procedures in place to allow access if requested. For example, the Santa Elena 

National Historic Landmark may be accessed by coordinating with installation 

staff. Access to Traditional Cultural Properties (TCPs) and archaeological sites 

is limited both to protect the sites from possible relic hunters and because these 

areas are often located within active training areas.

Other agencies report funding and other obstacles that limit their appreciation of the 

economic power of their historic properties. BIA reports it does not have a heritage 

tourism program to promote its historic properties. This is largely because the majority of 

the properties continue to be operational facilities. In addition, because these properties 

are also located within Indian reservations, the promotion of historic properties through 

heritage tourism is dependent on the values and interests of the respective tribes.

Measuring Economic Impacts of Historic Preservation, a report prepared under contract 

with the ACHP by PlaceEconomics, with funding from DOC, was published in 2011. 

In fulfilling the recommendation in the 2012 Report to the President, the study was 

updated and published with statewide and other economic impact studies in 2014 at 

www.achp.gov/economicstudies. The study included an extensive literature review of the 

preservation-economics link; interviews with parties in the public, private, and non-profit 

sectors; and an international symposium. The report found:

» Aspects of historic preservation have substantial economic benefits and costs, but 

they remain imperfectly understood and only partially documented.

» Research into the relationship between economics and historic preservation is 

critically needed.

» There are multiple constituencies for this information, many of whom need the data 

and information presented in different forms.

» Information must be consistent and credible, and its collection and dissemination 

ongoing.

» While the research and methodologies require scholarly robustness, the information 

needs to be presented in non-academic terms.

52 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
» While government needs to play an important role in data collection, analysis, and 

dissemination, it will probably be necessary for a number of private as well as public 

institutions to gather and evaluate the data. 

» However, there will need to be one entity that is responsible for annually releasing 

relevant metrics on a predictable basis.

The report recommended a public-private collaboration involving federal agencies, nonfederal parties, and academic institutions to create a long-term research, evaluation, and 

reporting plan; establish the baselines for indicators; systematize data collection; and 

undertake ongoing research and data collection. To date, no such formal collaboration 

with the federal government has been initiated to implement these recommendations, but 

non-federal parties and academic institutions continue to work in this area.

While federal agencies continue to struggle to articulate the economic impacts of their 

historic preservation activities, they continue to report with appropriate pride about 

their efforts to share the knowledge and experience of federal historic properties with the 

public in the course of daily business or in special events.

As an example, USGS supported the “Let’s Move Outside” initiative (www.letsmove.

gov/lets-move-outside) by hosting an all-day fish derby for children with special needs 

at the historic Leetown Science Center in West Virginia. Also the Center, established 

in 1930 as the U.S. Fisheries Experimental Station, hosted 100 local seventh and 

eighth grade students to learn about the history of the facility and the science of brook 

trout and fish diseases. 

In another example, USACE partnered with Black Rock Historical Society and Black 

Rock-Riverside Alliance to host the Centennial Celebration open house at the Black 

Rock Lock and Canal in New York. The event included guided tours of the lock, an 

interactive virtual lock model, historic photos and displays, information booths, and 

vintage music. Exhibitors at the event included the Black Rock Historical Society, 

Buffalo Maritime Center, Friends of the Buffalo Story, Lower Lakes Maritime Historical 

Society, and Preservation Buffalo Niagara. Twenty-seven artists sketched, painted, and 

photographed the historic lock, and their finished works were displayed at the open 

house and in a local gallery exhibit.

BUILDING PARTNERSHIPS

Federal agencies report on many partnerships with other federal agencies. The 

technical assistance provided by NPS and USACE to the federal family has generated 

knowledge and historic preservation outcomes in this reporting cycle. Federal agencies 

also frequently point to their consultative relationships with SHPOs, fundamental 

to the effective application of the Section 106 process for federal undertakings with 

the potential to affect historic properties. Some federal agencies also discuss their 

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 53
The National Park Service recognizes the 

connection between its investments in 

the preservation of historic properties in 

its ownership with the economic benefits 

of heritage tourism. While not all NPS 

park units feature historic properties or 

can characterize their visitors primarily as 

“heritage tourists,” many can. In its report, 

“2013 National Park Visitor Spending 

Effects: Economic Contributions to Local 

Communities, States, and the Nation,” the 

authors found that national parks play a 

major role in attracting and sustaining local 

businesses and communities. Prepared 

by economists Catherine Cullinane 

Thomas and Christopher Huber of the 

U.S. Geological Survey and Lynne Koontz 

of NPS, the report states that in 2013 

visitors spent more than $14.6 billion in 

communities near national parks, a sum 

that translates into 238,000 local jobs. 

NPS also reports that visitor spending data 

exists for each of the national parks, which 

shows the tremendous economic benefit 

that national park visitation provides to 

communities in terms of employment 

and sales. For example, in Calendar Year 

2013, Boston African American National 

Historic Site hosted 386,084 visitors who 

spent $21,280,800 in the local community. 

The direct effects of this spending include 

sales, income, and jobs in businesses selling 

goods and services directly to park visitors. 

In addition, visitor spending at this park 

generated 285 jobs. 

According to a 2012 study that NPS 

commissioned the consulting firm Tripp 

Umbach to conduct, the Essex National 

Heritage Area in Massachusetts annually 

contributed $153.8 million in economic 

impact, helped support 1,832 jobs, and 

provided $14.3 million in tax revenue. 

Additionally, the same study also found that 

combined together, the 21 National Heritage 

Areas in the Northeast Region produced 

an annual economic impact of $5.4 billion, 

supported more than 66,880 jobs, and 

provided $602.7 million in tax revenue. 

More information about the NPS Visitor 

Spending Effects Model is available online. 

(www.nature.nps.gov/socialscience/

economics.cfm)

View of the commercial district within Harpers Ferry National Historical Park, West Virginia

CASE STUDY

Measuring the 

Economic Effects 

of Federal Historic 

Preservation

FEDERAL AGENCY

National Park Service (NPS)

LOCATION 

Nationwide

54 | CHAPTER 3— CHAPTER 1—CURRENT STATE OF FEDERAL STEWARDSHIP INTRODUCTION AND BACKGROUND | 54
MONTANA

WYOMING

IDAHO

WASHINGTON

OREGON

NEVADA

UTAH

ARIZONA

NORTH 

DAKOTA

SOUTH 

DAKOTA

NEBRASKA

COLORADO

NEW MEXICO

TEXAS

OKLAHOMA

KANSAS

ARKANSAS

LOUISIANA

MISSOURI

IOWA

MINNESOTA

WISCONSIN

ILLINOIS INDIANA

KENTUCKY

TENNESSEE

MISS ALABAMA GEORGIA

FLORIDA

SOUTH

CAROLINA

NORTH CAROLINA

VIRGINIA

WV

OHIO

MICHIGAN

NEW YORK

PENNSYLVANIA

MD

DE

NJ

CONN

RI

MASS

MAINE

VT

NH

CALIFORNIA

ALASKA

HAWAII

DC

>$2 Billion

$1–2 Billion

$500 Million – $1 Billion

$100 – $500 Million

$50 –100 Million

<$50 Million

No Park Units

US VIRGIN ISLANDS

Created from data in “2013 National Park Visitor Spending Effects: Economic Contributions to Local Communities, States, and the 

Nation,” Natural Resource Report NPS/NRSS/EQD/NRR—2014/824

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 55
consultative relationships with Indian tribes, but rarely are these relationships described 

as “partnerships.” A few agencies are able to make use of volunteers and consider 

these important partnerships with their constituency. Finally, a few agencies reported 

partnerships with non-federal parties to identify, protect, and use historic properties in 

this reporting cycle. Several examples from the BLM report:

» Partnered with the Imperial Valley Desert Museum in Ocotillo, California, to 

rehouse all BLM artifacts (more than 20,000) under their care and supervision. 

Completed in 2013, the effort required the time of three BLM interns, 3,000 hours 

of volunteer time, and assistance from the local Girl Scout troop.

» Consulted with the Fort Mojave Indian Tribe to identify historic properties of 

significance to the tribe in Arizona. In the Mohave Valley Ethnographic Study, BLM 

is partnering with University of Washington and the Aha Macav Cultural Society 

to conduct interviews with tribal elders and traditional practitioners which will 

contribute to the completion of traditional cultural property nomination forms.

» Established new SiteWatch chapters in Carlsbad and Hobbs, New Mexico. 

SiteWatch trains volunteers to monitor archaeological sites and install anti-looting/

anti-vandalism signs.

» Partnered with Coppin State University, in accordance with Executive Order 

No. 13256, “President’s Board of Advisors on Historically Black Colleges and 

Universities,” and published “Finding History’s Forgotten People: The Presence of 

African Americans in the Settlement of Colorado, c. 1434 to 1954.”

GSA reports how it was able to partner with a SHPO and local preservation 

organization to ensure the preservation of a significant historic property. In Montgomery, 

Alabama, two of the Civil Rights Movement’s most significant buildings stand side by 

side. One is an elegant federal courthouse, from which U.S. District Judge Frank M. 

Johnson Jr. presided over crucial civil rights cases. The other is a modest Greyhound 

bus station where in 1961 young Freedom Riders used nonviolent methods to protest 

segregation. In the 1990s, GSA began planning for the expansion of the Federal Building 

and U.S. Courthouse. Recognizing that the bus station’s location next to the Frank 

M. Johnson courtroom offered unique opportunities for interpreting a shared history, 

GSA, the Alabama Historical Commission, the U.S. District Court, and members of 

the Greyhound Bus Station Advisory Committee devised a plan to preserve the bus 

station—and GSA agreed to lease the station to the Historical Commission for a small 

fee. In 2011, the Freedom Rides Museum opened to the public, and in October 2012, 

the partners received the National Trust for Historic Preservation/ACHP Award for 

Federal Partnerships in Historic Preservation.

TVA reports it has established “A Thousand Eyes” archaeological outreach program, 

through which volunteers receive formal training in monitoring select archaeological sites 

on TVA land. TVA expects this pilot program to begin in 2015. 

The NPS reports that, more than 246,000 volunteers donated 6.7 million hours of 

service to national parks at a total value of $134 million in 2013. The Urban Archeology 

Corps is an eight-week summer work program for diverse youth, ages 15-25, and is a 

Students enjoy the USS Midway Museum 

in California in a program sponsored in 

part by the U.S. Navy.

CREDIT: USS MIDWAY MUSEUM

56 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
Through an innovative disposal transfer, 

operating agreement, and public-private 

partnerships, the Clara Barton’s Missing 

Soldiers Office Museum in the District of 

Columbia, opened to the public in 2014 

with minimal federal funding. 

The Clara Barton Missing Soldiers Office 

was originally rediscovered by GSA in 1996, 

when the building housing it was scheduled 

for demolition. Located on 7th Street, NW, 

the site is the location where Clara Barton 

lived during and immediately after the Civil 

War. She used this property not only as a 

place to live but also to store the supplies 

she received for her work on the battlefield, 

and later as an office to handle correspondence concerning missing soldiers. 

Based on the discovery of the significance 

and integrity of the historic property and 

as a result of Section 106 consultation, 

GSA was able to reconsider its plans to 

demolish the building, and, instead, the 

agency sold the property in 2001 to 

Jefferson at Penn Quarter, LLP, retaining 

a preservation easement on the façade 

and portions of the interior. The grantee 

CASE STUDY

Preservation 

Through Disposal 

and Partnership

FEDERAL AGENCY

General Services 

Administration (GSA)

LOCATION 

District of Columbia

CHAPTER 1—INTRODUCTION AND BACKGROUND | 57

GSA restored and partners with the new building owner and the National Museum 

of Civil War Medicine to provide public access to Clara Barton Missing Soldiers Office, 

Washington, D.C.

CREDIT: OLBN, INC./COURTESY GSA

CREDIT: OLBN, INC./COURTESY GSA

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 57
agreed to stabilize, adaptively reuse for 

museum and commercial use, and allow 

public access to the third floor spaces 

occupied by Barton which would be 

restored by GSA as a museum. 

In 2005, JPI Development completed an 

$8 million stabilization and rehabilitation, 

which added a rear elevator, egress 

stairs, toilets, a replicated façade, basic 

buildings systems, and fire suppression. 

In 2007, JPI sold the property to 

Douglas Development, which assumed 

responsibility for maintenance of the 

exterior in perpetuity and base building 

system operating costs. 

GSA’s imaginative redevelopment met 

the community’s need for increased 

residential density while taking advantage 

of the building’s proximity to mass transit, 

museums, and entertainment. GSA 

managed the $1.8 million museum quality 

conservation and selective restoration, 

completed in 2013, using sales proceeds 

set aside for Square 457 mitigation and 

historic building outlease funds. 

Completed by a minority-owned, small 

business known for its accomplishments 

in cutting-edge historic building 

documentation, preservation, and 

sustainability, the restoration also 

employed an array of small business 

subcontractors as conservators, craftsmen, 

and fabricators to retrofit spaces once 

used by Barton with mechanical, electrical, 

and plumbing systems for the first time. 

Under an operating agreement with 

GSA, the National Museum of Civil War 

Medicine is funding museum exhibits, 

educational programs, marketing, and 

daily operations (www.civilwarmed.org/

clara-barton-museum/about-clara-bartonsmissing-soldiers-office/).

58 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
collaboration with Groundwork Anacostia River DC. Participants are exposed to a broad 

range of what archaeology and historic preservation “look like” in the parks. In 2014, 

nine participants explored Fort Dupont Park, Anacostia Park, Fort Chaplin Park, and 

Fort Mahan Park, among others, researching the history of these parks and conducted 

archaeology and oral history interviews under the theme “Changing Landscapes.” 

Participants focused on the changing landscape of the parks and the surrounding 

neighborhoods. They also conducted archival research, archeological excavation, artifact 

processing, and site visits to numerous and varied NPS park units. Finally, these youth 

participated in training workshops, including Allies for Inclusion Diversity, Oral History, 

Videography/Photography, and GPS/GIS.

The Science and Technology Directorate of DHS reports that it partners with lighthouse 

and military history enthusiasts to allow exterior tours of Plum Island Lighthouse and 

Fort Terry. This agency also recently partnered with the Southold Historical Society to 

publish, “A World unto Itself: the Remarkable History of Plum Island, New York.”

Unfortunately, partnerships for historic preservation are not always successful. The 

National Cemetery Administration of VA reports that in the reporting cycle two 

partnerships intended to rehabilitate and reuse two historic buildings have failed:

» VA issued a 20-year Revocable License for Non-Federal Use of Real Property to the 

Keokuk Historic Preservation Commission in 1999. The partner was to rehabilitate 

and reuse the 1871 historic lodge at Keokuk National Cemetery in Iowa as a 

welcome center and museum/war memorial using state grant funds. The partner 

gutted the building, but work ceased in 2010. In May 2012, VA revoked the license 

and contracted with NPS to mothball the building.

» VA executed a 10-year lease with the Soldiers Home Foundation in 2010. The 

partner committed to rehabilitate and reuse the historic 1929 “Roundhouse” at 

Wood National Cemetery in Wisconsin as a reception space. Although the required 

consultation with the SHPO appears to have been initiated by the partner, no work 

has been completed to date, and the building’s condition has deteriorated.

SUMMARY

The 2014 progress reports received by the ACHP on federal agency efforts to identify, 

protect, and use historic properties demonstrate continued program improvement and 

detail the efforts agencies make to manage properties in accordance with the goals of 

the NHPA and EO 13287. While many challenges remain and new opportunities are 

emerging, the ACHP notes significant progress in the integration of historic property 

data and concerns into agency planning with historic preservation outcomes. 

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 59
CHAPTER 4: FI NDI N GS AND 

RECOMMENDATIONS

THIS CHAPTER CONTAINS THE ACHP’S FINDINGS regarding the 

current state of federal historic property management and recommendations for 

improvements to be implemented over the next three years. While the primary basis 

for these conclusions are the 2014 progress reports submitted by federal agencies, these 

findings are also informed by the ACHP’s extensive interaction with federal agencies and 

preservation partners in daily activities. 

The 2014 progress reports reaffirmed that federal real property portfolios include a 

broad and diverse range of historic properties that can only be effectively managed 

with a similarly diverse set of protocols, procedures, and other tools. Agencies have 

acknowledged that strategies for the management of one property type or even one 

specific property may not be applicable to others, and the original uses of historic 

properties, especially those of a scientific or technical nature, present obstacles to 

adaptation for current needs. While most agencies have tools and procedures at their 

disposal that are sufficiently diverse to prepare them for most challenges, many agencies 

continue to encounter situations that cannot be effectively addressed by current business 

models or standard federal practices. The ACHP will continue to encourage federal 

agencies to review their policies and procedures for real property management to ensure 

they are adequately flexible to provide for historic preservation outcomes. 

In 2015, the Veterans Health 

Service (VA) completed the 

Section 106 review of its 

long-range development plan 

for the historic San Francisco 

VA Medical Center, California, 

with the execution of a 

Programmatic Agreement to 

guide future undertakings.
While many agencies are improving the management and condition of their historic 

properties, others face challenges when historic preservation is outside their core mission. 

For agencies that have successfully integrated stewardship into their strategic plans, the 

preservation, enhancement, and sustainable use of historic properties have proven to 

be assets for meeting mission needs. Historic properties have also proven to be energy 

efficient, sustainable, and often adaptable and resilient to climate change.

The 2014 progress reports continue to demonstrate that historic preservation initiatives 

which involve partnerships with non-federal entities can bring social and economic 

benefit to both agencies and local communities. While some agencies are articulate 

regarding their partnerships with state, tribal, and local communities and the private 

sector, others do not describe such partnerships or demonstrate awareness of the 

opportunities they offer. Improved awareness of and appreciation for the social and 

economic value of partnerships will foster better management practices that will benefit 

these agencies, historic properties, and the American people.

The following findings and recommendations are the priorities the ACHP will address 

to improve the federal preservation program and respond to emerging issues in the 

management of historic properties.

FINDING NO. 1: FEDERAL PROPERTY CONSOLIDATION AND 

REALIGNMENT

Integrating historic property stewardship in federal agency strategic planning for the 

consolidation and realignment of real property portfolios improves historic preservation 

outcomes.

When an agency maintains comprehensive inventory data on the historic properties in its 

ownership and utilizes this data in the consultation process for Section 106 compliance, 

the agency can make informed decisions about which buildings, structures, and areas of 

land to utilize and in what manner. Historic properties are more likely to be deemed an 

asset by an agency when considered in this proactive manner. 

Agencies are improving their ability to integrate inventory data into real property data 

management systems, including the FRPP. Continued investment of resources in this 

area, along with clear guidance from the FRPC, is building the foundation for improved 

strategic management of federal historic properties in the future. In order to create 

efficiencies in infrastructure permitting and review and to improve environmental 

outcomes, a national inventory of historic properties, managed by State and Tribal 

Historic Preservation Officers in collaboration with NPS, would not only address 

infrastructure permitting needs but also be useful for real property managing agencies 

in their program and project planning. Funding for this critical effort is included in the 

FY 2015 Administration budget (See Budget Data Request No. 13-32: Infrastructure 

Permitting (2013)).

Federal agencies have been actively identifying real property for disposal and demolition 

in this reporting cycle. Many of these properties include historic buildings and structures. 

Excess acreage may also contain archaeological sites, cultural landscapes, or other 

properties of religious or cultural significance to Indian tribes or Native Hawaiian 

The ACHP will 

continue to 

encourage federal 

agencies to review 

their policies and 

procedures for real 

property management 

to ensure they are 

adequately flexible 

to provide for 

historic preservation 

outcomes.

CHAPTER 4—FINDINGS AND RECOMMENDATIONS | 61
organizations. Agencies continue to report, as they did in 2011, that the identification of 

real property for disposal is not generally informed by historic property inventory data or 

stewardship values. As a result, the agency often only begins considering the significance 

of any historic properties and the potential reuse of historic buildings and structures 

after the property is identified for disposal, which may limit the range of alternatives 

available for the agency to consider. More agencies would benefit from strategic plans that 

encourage consideration of these values prior to a disposal proposal. 

The challenge of reusing historic buildings and structures is particularly acute when 

those buildings and structures are associated with a highly technical or scientific 

mission. Once that mission is obsolete, the properties associated with it are often 

viewed as obsolete as well. In 1991, the ACHP published guidance, “Balancing Historic 

Preservation Needs with the Operation of Highly Technical or Scientific Facilities.” 

(www.achp.gov/pubs-scitech) While this guidance is largely still applicable, agencies 

would benefit from access to more recent success stories of creative adaptive reuse of 

these specialized historic properties. 

In some cases, however, agencies have determined it is not feasible to dispose of a 

historic property or that the stewardship responsibilities require the retention of 

federal ownership. It is often not feasible to dispose of an unused building or structure 

embedded in a federal facility when the parcel cannot be separated and made accessible 

for disposal to a non-federal party. In such cases, some agencies have found that 

outleases–as authorized by an EUL authority, Section 412 of the General Provisions 

Consolidated Appropriations Act, or Section 111 of the NHPA–are effective tools 

to offset costs of historic properties while ensuring the long-term preservation and 

stewardship of historic properties. These outlease solutions can result in historic 

preservation outcomes, yet agencies face some impediments to using this option. 

As reported in the 2012 Report to the President, Section 412 allows GSA to create 

outlease-leaseback relationships with private companies that provide the capital to 

preserve and upgrade important historic buildings. However, budget scoring rules, 

developed jointly by OMB, the Congressional Budget Office, and the House and 

Senate Budget Committees require the government costs for the entire lease term 

to be financed up front in the first year of the lease. This requirement has limited 

GSA’s ability to use private financing to leverage the equity value of government assets, 

resulting in greater cost to taxpayers. Greater flexibility with the application of the 

budget scoring rules for Section 412 leases would enable GSA to pursue the long-term 

cost benefits and other advantages of federal ownership and keep these important 

federal buildings occupied and viable. 

In addition, according to OMB’s “Freeze the Footprint” guidance, a federal agency shall 

not increase on an annual basis the size of its domestic real estate inventory, measured 

in square footage, for space predominately used for offices and warehouses. Any growth 

in total office or warehouse space must be offset by a corresponding decrease through 

declaration of excess, disposal, or closed/realigned as part of a DOD BRAC process. An 

agency may not use as an offset properties that the agency has “mothballed” or those 

subject to EULs and outleases, including Section 412 and Section 111 leases. This 

guidance discourages agencies from pursuing outleasing as a preservation option for 

An agency may 

not use as an 

offset properties 

that the agency 

has “mothballed” 

or those subject 

to enhanced use 

leases and outleases, 

including Section 

412 and Section 111 

leases. This guidance 

discourages agencies 

from pursuing 

outleasing as a 

preservation option 

for unused historic 

properties. 

62 | CHAPTER 4—FINDINGS AND RECOMMENDATIONS
unused historic properties. Federal agencies reported that the application of the “Freeze 

the Footprint” guidance, in the absence of historic preservation-informed strategic 

planning, has resulted in the demolition of many historic buildings and structures 

that might have been useful to non-federal parties and could have self-supported their 

costs through a Section 412 or Section 111 lease. This policy, which may be intended 

to encourage reuse, has actually resulted in demolition and disposal without ensuring 

the preservation of many historic properties. The current policy does not achieve an 

appropriate balance between historic preservation stewardship and the need to limit the 

footprint of the federal government.

To Address This Finding the ACHP Will:

» Continue to advise the FRPC on the collection of data related to historic properties 

in the FRPP.

» Work collaboratively with NPS, State Historic Preservation Officers, and Indian 

tribes to develop and coordinate a national inventory of historic properties, to create 

efficiencies in infrastructure permitting and review, and improve environmental 

outcomes both on and off federal land (In FY 2015 Administration Budget; See also 

Budget Data Budget Data Request No. 13-32: Infrastructure Permitting (2013)).

» Continue to advise federal agencies on best practices that encourage proactive and 

useful inventory data collection to provide opportunities for the protection and use 

of historic properties.

» Advise Congress and the Administration on the implications of legislative proposals 

to codify federal property management initiatives on historic properties and 

encourage proper integration of historic preservation consideration and values.

» Continue to provide guidance and success stories demonstrating how highly 

technical and scientific historic properties are adaptively reused by federal agencies.

Recommendations for Others:

» Federal agencies should request adequate funding to identify historic properties on 

federal land to meet the requirements of Section 110 of the NHPA.

» The Administration should continue its support for and Congress should 

appropriate funding for a national inventory of historic properties to create 

efficiencies in infrastructure permitting and review and to improve environmental 

outcomes both on and off federal land (In FY 2015 Administration Budget; See also 

Budget Data Request No. 13-32: Infrastructure Permitting (2013)).

» Federal agencies should ensure complete and accurate historic property inventory 

data is collected and considered before real property consolidation decisions are 

made, including the decision to leave a historic property unused. 

» OMB, in consultation with GSA, the ACHP, and other affected agencies, should reexamine the application of Section 412 scoring rules as applied to historic buildings 

CHAPTER 4—FINDINGS AND RECOMMENDATIONS | 63
and pursue changes to leverage equity value and facilitate the outlease of important 

federal historic properties.

» OMB, in consultation with GSA, the ACHP, and other affected agencies, should 

consider changes to the “Freeze the Footprint” offset guidance to increase flexibility 

for long-term, self-supporting Section 111 and Section 412 leases of historic 

properties to non-federal parties.

» GSA, NPS, and VA should continue to collaborate with the ACHP to encourage 

federal agencies to use existing federal leasing and reuse authorities, including 

Section 111 and Section 412, to use federal historic properties to promote economic 

development.

FINDING NO. 2: ENERGY EFFICIENCY AND SUSTAINABILITY

Agencies would benefit from examples of creative solutions developed for “green design” 

rehabilitation projects of federal historic buildings and structures.

As noted in 2012, the Administration continues to advocate for a federal government 

and workforce that reduces energy consumption and increases energy efficiency. In 

this reporting cycle, agencies are continuing to apply the requirements of the Energy 

Independence and Security Act of 2007 and EO 13514 and to pursue “green design” 

solutions in all their real property decision making. 

While many agencies continue to struggle to view historic assets as sustainability assets, 

some agencies have demonstrated that historic buildings can be used to meet federal 

energy and efficiency goals. Historic buildings and structures in federal ownership 

were often constructed to high standards in part due to the availability of high quality 

materials, access to local craftsmen, and relatively low cost of skilled labor when 

constructed. They were also typically constructed to be responsive to local climates. 

Agencies should continue to consider the strong reinvestment potential of historic 

buildings and structures, that, once rehabilitated, support modern energy efficiency 

goals and long life-cycle use. Federal historic buildings and structures are often in 

“sustainable locations,” as defined by the Department of Transportation in its EO 13514 

guidance, with access to existing utilities and transportation. For these reasons, historic 

properties can play an important part in the energy efficiency and sustainability future 

of the federal government.

Federal agencies are incorporating green design solutions in a wide variety of new 

construction and rehabilitation projects. Some agencies have used the standards 

developed by the U.S. Green Building Council (USGBC) and its LEED certification 

process for guidance on energy performance improvements for specific historic properties. 

In 2012, the ACHP and NPS participated in the USGBC update process for the LEED 

rating system, advocating for acknowledgement of the durability of historic buildings, 

materials, and systems. GSA has demonstrated that a rehabilitated federal historic 

building can meet the highest standards for green design, achieving LEED Platinum 

certification. It is important to note, however, that green design may meet the goals of 

energy efficiency and sustainability, but not be LEED certified. 

Agencies should 

continue to 

consider the strong 

reinvestment potential 

of historic buildings 

and structures, that, 

once rehabilitated, 

support modern 

energy efficiency goals 

and long life-cycle use.

64 | CHAPTER 4—FINDINGS AND RECOMMENDATIONS
The National Trust for Historic Preservation and other private sector preservation 

partners continue to develop valuable research and resources regarding the sustainable 

qualities of historic buildings and structures. These resources may be of use to federal 

agencies, particularly when considering reinvesting in a historic property for continued 

use or adaptive reuse. 

To Address This Finding the ACHP Will:

» Work with CEQ’s Steering Committee on Federal Sustainability and collaborate 

with GSA and NPS (specifically, the National Center for Preservation Technology 

and Training) to collect stories of successful green rehabilitation of historic buildings 

and structures of all sizes and share them with federal agencies.

» Partner with CEQ, Environmental Protection Agency, GSA, National Trust for 

Historic Preservation, National Conference of State Historic Preservation Officers, 

and other parties to disseminate private-sector energy efficiency and sustainability 

research and solutions for historic properties to federal departments and agencies.

Recommendations for Others:

» Federal agencies planning and designing energy efficient and sustainable buildings 

and structures, including those seeking LEED certification, should acknowledge the 

durability of historic buildings, materials, and systems and consider reusing historic 

properties when feasible.

FINDING NO. 3: CLIMATE CHANGE AND ADAPTION

Systemic efforts by federal agencies to identify and prepare for the threats of climate change 

and to maximize the resilience of historic properties are necessary stewardship responsibilities.

In this reporting cycle, federal agencies prepared Climate Change and Adaption 

Plans as required by EO 13653. These plans provide an inventory and assessment of 

proposed and completed changes to their land- and water-related policies, programs, and 

regulations necessary to make watersheds, natural resources and ecosystems, and the 

communities and economies that depend on them be more resilient to climate change. 

However, in these plans, most agencies did not address the potential threats of climate 

change to historic properties in their ownership nor actions the agency could take to 

prepare historic properties to be more resilient. 

One reason such consideration of historic properties was not included in the plans is that 

EO 13653 did not specifically require it. While the Preserve America EO and NHPA 

support the understanding that historic properties are integral parts of the “communities 

and economies that depend on them” as referenced in EO 13653, without the specific 

requirement to consider historic properties, most federal agencies did not include such 

consideration in their plans. 

There is no doubt that the effects of climate change may be detrimental to historic 

properties. Historic buildings and structures in coastal storm impact zones or river 

floodways face the threat of wind and water damage as those events increase in frequency. 

Threats to federal 

historic properties 

need to be 

considered with 

the same rigor as 

the stewardship of 

watersheds, natural 

resources, and 

ecosystems. 

CHAPTER 4—FINDINGS AND RECOMMENDATIONS | 65
Archaeological sites in floodways are also threatened by erosion which can lead to loss 

of integrity and increased potential for looting or vandalism. Historic battlefields and 

traditional cultural landscapes may be damaged by federal efforts to fight wildfires as 

cycles of drought contribute to more of those events. Such threats to federal historic 

properties need to be considered with the same rigor as the stewardship of watersheds, 

natural resources, and ecosystems. In addition, since many government office buildings 

and warehouses are historic properties, the consideration of historic properties should 

also be part of agency plans to maintain operations in adverse conditions.

In its invitation to the ACHP to join the Council on Climate Preparedness and 

Resilience established by EO 13653, CEQ acknowledged “many of the United States’ 

iconic landmarks and heritage sites are at risk to the impacts of climate change” (October 

31, 2014). In participating in this Council, the ACHP brings its knowledge of federal 

historic property stewardship gained from Section 3 reporting and its understanding of 

non-federal historic preservation concerns gained from its membership, partners, and 

experience in Section 106 consultations. The ACHP also is looking for opportunities to 

integrate climate change policies and planning with the Unified Federal Review process, 

Federal Infrastructure Permitting and Review Process Improvements, and other related 

initiatives. Participation on the Council by the chairman of the ACHP along with other 

senior officials of federal agencies provides an opportunity for the ACHP to continue 

to advocate for consideration of historic properties in climate change preparedness and 

resilience at the appropriate policy level. 

To Address This Finding the ACHP Will:

» Advocate through its participation in the Council on Climate Preparedness 

and Resilience, other related initiatives, and daily activities regarding federal 

historic property stewardship to help ensure that policy and planning for climate 

change preparedness and resilience adequately address preservation of America’s 

irreplaceable historic properties.

Recommendations for Others:

» The Administration should direct federal agencies to review their existing 

Climate Change and Adaption Plans to identify threats to historic properties and 

incorporate strategies to prepare to protect those properties and to maximize their 

resilience.

FINDING NO. 4: FEDERAL PRESERVATION PROGRAMS 

IN THE 21ST CENTURY

Agency-wide historic preservation policies and leadership commitment to their implementation 

create a culture of stewardship, facilitate the allocation of resources to meet responsibilities, 

and improve preservation outcomes.

In the 2009 Report to the President, the ACHP found “Agency strategic plans, which are 

prepared by senior policymakers to assist in fulfilling the agency’s mission, still frequently 

do not address historic property management needs or establish goals for improvement 

66 | CHAPTER 4—FINDINGS AND RECOMMENDATIONS
at the appropriate level.” In the 2012 Report to the President, the ACHP added to 

this finding, “As a result, many agencies find it difficult to identify adequate resources 

to effectively resolve conflicts between NHPA and other statutory requirements.” The 

2014 progress reports support the need for the integration of historic preservation into 

agency policies and planning as well. The ACHP’s experience with a variety of agencies 

demonstrates that greater frequency and success regarding historic preservation outcomes 

is more likely when agencies have integrated stewardship into strategic planning. The 

preservation success stories highlighted in this report—especially the NASA, AFRH, 

and GSA case studies—each demonstrate an agency culture where historic properties 

are protected, enhanced, and used as agency assets.

Section 3(e) of the Preserve America EO requires each agency to maintain a 

designated SPO at the assistant secretary, deputy assistant secretary, or equivalent 

level. Engaged SPOs are positioned to provide agency-wide leadership to develop 

and implement policies that integrate historic preservation into strategic planning, 

encourage reuse of historic buildings and structures, and maximize opportunities to 

partner with appropriate state, local, and tribal governments and other non-federal 

parties to meet historic preservation goals. SPOs are also positioned in the agency 

to ensure the allocation of adequate funds and personnel for historic preservation 

programs and to facilitate the development of creative cost-sharing approaches with 

partners. When SPOs provide leadership to integrate the policies, procedures, and 

practices of the NHPA and the Preserve America EO into their agency program 

activities, historic preservation and their agency mission are more efficiently and 

effectively advanced as envisioned in Section 1 of the EO.

As discussed in Finding No. 1 of this report, to meet the requirements for the 

identification and evaluation of historic properties in Section 110 of the NHPA, agencies 

report that more funding and personnel are needed. These proactive identification efforts 

are necessary to inform agency real property strategic planning and advise non-federal 

parties–such as energy developers, energy transmission providers, and transportation 

agencies and providers–who may propose undertakings on federal lands. 

Without such data, agencies continue to report that most efforts to identify and protect 

historic properties are conducted as part of or as a result of Section 106 reviews. This 

reactive planning process requires consideration of means to avoid, minimize, and 

mitigate adverse effects of federal undertakings on historic properties with non-federal 

stakeholder input. When the Section 106 process is initiated late in the planning 

process, as is often the case, complete avoidance of adverse effects to historic properties 

may not be a viable alternative. Improved data at the outset of the process and early 

initiation of the Section 106 review process maximizes opportunities for historic 

preservation outcomes as well as avoiding the costs and time delays often associated with 

consideration of historic preservation issues at the eleventh hour. 

Federal efforts to meet Sections 106 and 110 of the NHPA are improved when agencies 

provide for the participation of representatives of diverse communities. The changing 

demographics of America pose opportunities as well as challenges for the national 

historic preservation program. The diversity of cultures in our country shape and 

enrich the American experience, and the federal government can continue to encourage 

CHAPTER 4—FINDINGS AND RECOMMENDATIONS | 67
wider involvement and representation in determining what historic sites are worthy 

of recognition and preservation; how history and cultural heritage should be valued, 

interpreted, and preserved; and how we can ensure the American public as a whole can 

take advantage of the programs and tools created under the NHPA. 

The ACHP notes that several federal agencies with significant inventories of historic 

properties did not submit progress reports as required by the Preserve America EO, or 

submitted well after the September 30 deadline (See Appendix C of this report). These 

reports are a critical tool for the ACHP, DOI, and the Administration to understand 

trends and patterns in the stewardship of historic properties in federal ownership. 

Effective compliance with the EO and pursuit of its goals can help advance important 

Administration policies and initiatives.

To Address This Finding the ACHP Will:

» Continue to develop and implement performance measures to assess the overall 

effectiveness and efficiency of the Section 106 process and to survey practitioners’ 

experience in complying with the requirements of the Section 106 regulations.

» Consistent with its 2014 Strategic Plan, continue to issue guidance and provide 

education, training, and outreach to support the effective participation of stakeholders 

and the public in the Section 106 process and to promote the effective consideration of 

historic preservation concerns in federal program and project planning.

» Encourage other federal agencies to build a preservation program more inclusive of 

the diverse communities and culture of the nation.

Recommendations for Others:

» Designated SPOs should provide agency leadership to integrate the policies, 

procedures, and practices of the NHPA and the Preserve America EO into their 

agency program activities so that historic preservation and their agency mission are 

more efficiently and effectively advanced as envisioned in Section 1 of the Preserve 

America EO.

» The Administration should reaffirm the purpose and intent of EO 13287 and 

encourage federal agencies with real property responsibilities to document their 

progress by submitting a comprehensive and timely triennial report to the ACHP 

and the Secretary of the Interior.

SUMMARY

As they continue to examine their historic preservation programs to determine how 

to maintain, strengthen, and improve their stewardship and productive use of historic 

properties, federal agencies are encouraged to support the ACHP in implementing these 

recommendations. Agencies should continue to establish and meet specific, measureable 

goals for improving their efforts to identify, protect, and use historic properties and 

report on their progress in addressing these challenges and implementing these 

recommendations in 2017, the next reporting cycle.

68 | CHAPTER 4—FINDINGS AND RECOMMENDATIONS
C H AP T E R 5 : TOWAR D A 

COMMON GOAL

The Preserve America EO requires each agency with real property management 

responsibilities to prepare a triennial report on its progress in identifying, protecting, and 

using historic properties in its ownership and to make the report available to the ACHP 

and the Secretary of the Interior. These reports are vital to the improvement of federal 

historic properties management. They assist the ACHP and the Administration in 

measuring the progress and commitment of agencies in achieving the goals of the NHPA 

and the EO and formulating effective strategies, and they contribute to the ACHP’s 

ability to report triennially to the President.

The 2014 Section 3 progress reports represent the fifth round of reporting by federal 

agencies under EO 13287 and continue to demonstrate a clear commitment to 

improve federal stewardship of historic properties. Agency reports provide information 

on historic property inventories in accordance with the goals of NHPA and EO 

13287 and demonstrate examples of successes in integrating historic preservation and 

sustainability goals. While challenges remain, the ACHP notes significant progress 

in the integration of historic property data and concerns into agency planning with 

historic preservation outcomes.

As federal agencies strive to carry out their responsibilities under Section 110 of the 

NHPA and to develop and update existing comprehensive inventories of historic 

properties in the 21st century, many are identifying properties with more diverse areas 

The historic and rehabilitated 

International Institute of 

Tropical Forestry in San Juan, 

Puerto Rico, is LEED Gold 

certified and symbolizes how 

natural resource conservation, 

environmental protection, 

and historic protection are 

all part of the Forest Service 

sustainability ethic.

CREDIT: FS
of significance than ever before. Due to the passage of time, some properties which were 

not considered significant in the past may need to be re-evaluated in a new context. This 

evolution of significance requires agencies to think broadly when evaluating properties 

and to involve diverse stakeholders and potential preservation partners representing the 

communities and cultures that value them. 

The changing demographics of America pose opportunities as well as challenges for 

the national historic preservation program. The diversity of cultures in the country 

shape and enrich the American experience. The federal government can continue to 

encourage wider involvement and representation in determining what historic sites 

are worthy of recognition and preservation; how history and cultural heritage should 

be valued, interpreted, and preserved; and how it can ensure the American public as a 

whole can take advantage of the programs and tools created under the NHPA. Through 

partnerships, agencies can leverage the investments and stewardship of the federal 

government with the enthusiasm and resources of diverse non-federal parties to meet 

historic preservation goals and ensure public access to important historic properties. The 

ACHP is pursuing efforts in all aspects of its work to build a more inclusive preservation 

program, and through those efforts encourage other agencies to do so as well.

The potential effects of climate change on historic properties may seem daunting to 

federal agencies. It is imperative that as stewards of historic properties, agencies plan to 

minimize the potential for disruption and loss and to maximize resiliency. Since 2012, 

the recovery from Hurricane Sandy has taught agencies many lessons, which are still 

being analyzed and shared, and the application of which will improve federal stewardship 

of historic properties.

The ACHP is committed to carrying out the identified recommendations of this report 

and working closely with other agencies that share a common commitment to this 

process over the next three years. On a daily basis, the Federal Property Management 

Section of the ACHP’s Office of Federal Agency Programs works closely with federal 

property managers in meeting their responsibilities and improving preservation 

outcomes under Section 106 and 110 of the NHPA. In Fiscal Years 2015 through 

2017, the ACHP will continue to partner with property managing agencies, SPOs, 

Federal Preservation Officers, and agency leadership to identify opportunities for greater 

protection of historic properties in federal ownership. It will also seek new partnerships 

to support Administration initiatives to advance federal identification, protection, and 

use of historic properties while meeting goals for sustainability, climate change and 

adaptation, and fiscal responsibility.

The required reporting under EO 13287 has proven to be a useful tool for identifying 

the current issues and status of federal historic property management and the progress 

federal agencies have made in meeting the goals of the NHPA and the EO. At its 

inception, the ACHP Report to the President was a milestone in federal stewardship. 

It provided the first opportunity for agencies to examine their own achievements 

and receive an independent evaluation from the ACHP of these efforts. This fourth 

triennial report has demonstrated that federal property managers are using EO 13287 

to strengthen their preservation programs and inspire their own leadership to meet 

these goals. The ACHP anticipates that the recommendations within this report, once 

The continued 

productive use 

of federal historic 

properties is a 

solution for energy 

efficient, sustainable, 

adaptable, and 

resilient real property 

needs. 

70 | CHAPTER 5—TOWARD A COMMON GOAL 
Issued February 10, 2014, the NPS 

Director’s memo, “Climate Change 

and Stewardship of Cultural Resources” 

addresses three key questions: (1) what 

is climate change adaptation for cultural 

resources; (2) how should the NPS make 

decisions related to cultural resources in 

light of climate change; and (3) how does 

the NPS communicate regarding climate 

change science and impacts. Among other 

provisions, it requires that all identified 

cultural resources be evaluated for their 

vulnerability and significance so that 

management decisions take into account 

those resources that are both significant 

and most at risk. 

NPS, whose primary mission is to 

preserve America’s natural and cultural 

heritage, is developing and implementing a 

cultural resources climate change response 

strategy that integrates cultural resource 

management with broad climate science, 

adaptation, mitigation, and communication 

efforts. Cultural resources, which include 

archaeological sites, cultural landscapes, 

ethnographic resources, historic and 

prehistoric structures, and museum 

collections, have distinct considerations 

with respect to climate change. Most are 

fixed in place or derive much of their 

significance from the place within which 

they were created. Many are non-living, 

and all are unique. As a result, the capacity 

of cultural resources to adapt to changing 

environments is limited.

Impacts to cultural resources from climate 

change range from coastal erosion and 

storm damage to effects of wildfires, 

floods, melting permafrost, and more 

rapid deterioration due to changing 

rain and temperature patterns. Cultural 

resources have always been subject to 

these types of environmental forces. 

However, observed and projected climate 

change trends are a great concern as 

these forces accelerate, intensify, and 

combine in new ways that are increasing 

the rate of loss of cultural resources. 

These trends heighten the urgency for 

the NPS to survey climate-vulnerable 

areas, develop appropriate preservation 

and documentation techniques, and learn 

from the history and prehistory these 

resources contain. With so many cultural 

resources entrusted to its care, NPS 

provides leadership nationwide in historic 

preservation and cultural resource 

management in regard to climate change. 

Cultural resources are irreplaceable 

indicators of the wide array of lifeways, 

ideas, beliefs, practices, and experiences 

that, over time, have led to the world we 

live in today. The NPS strategy for cultural 

heritage and climate change addresses 

both the impacts of climate change on 

cultural resources as well as the many 

forms of information about human history 

and human-environment interactions 

they contain. NPS is working to adapt 

NPS is planning for climate change adaption and resiliency at the Casa Grande Ruins National 

Monument in Coolidge, Arizona.

CASE STUDY

Protecting Historic 

Properties From the 

Effects of Climate 

Change

FEDERAL AGENCY

National Park Service (NPS)

LOCATION 

Nationwide

CREDIT: NPS

CHAPTER 1—INTRODUCTION AND BACKGROUND | CHAPTER 5—TOWARD A COMMON GOAL | 71 71
cultural resource stewardship, management, 

research, and interpretive practices to the 

challenges of climate change.

Cultural resources are also an integral part 

of how NPS interprets climate change, 

including the Every Place has a Climate 

Story Initiative. Developing instructional 

products on the progression of climate 

change and engaging with long-term and 

ongoing relationships between humans 

and their environments will help park staff 

more fully share these impacts and lessons 

learned with park visitors. 

During its “Preserving Coastal Heritage 

Worksession,” which occurred in New 

York, April 3-4, 2014, NPS recognized it 

is at a critical juncture in this process and 

sought help and input from an invited 

group of participants with real-world 

expertise in addressing the powerful 

impacts of climate change on the human 

environment. 

More than 70 federal, state, local, nonprofit, and university leaders met 

to discuss the decision process for 

managing cultural resources impacted 

by climate change. One of the goals of 

the work session was to create a draft 

decision framework that will help NPS 

choose realistic options for managing 

vulnerable cultural resources, including 

historic buildings and structures, cultural 

landscapes, archaeological sites, museum 

collections, and ethnographic resources. 

The first portion of this framework, 

focused on cultural landscapes, is currently 

planned for public release in spring 2015.

EXPERIENCE YOUR AMERICATM

Cultural resources, which include archeological sites, cultural landscapes, ethnographic resources, historic and prehistoric structures, 

and museum collections, have distinct considerations with respect to 

climate change. Most are fixed in place or derive much of their significance from the place within which they were created. Many are nonliving, and all are unique. As a result, the capacity of cultural resources 

to adapt to changing environments is limited. 

Impacts to cultural resources from climate change range from coastal 

erosion and storm damage to effects of wildfires, floods, melting 

permafrost and more rapid deterioration due to changing rain and 

temperature patterns. Cultural resources have always been subject to 

these types of environmental forces. However, observed and projected 

climate change trends are a great concern as these forces accelerate, 

intensify, and combine in new ways that are increasing our rate of loss 

of cultural resources. These trends heighten the urgency for the NPS to 

survey climate-vulnerable areas, develop appropriate preservation and 

documentation techniques, and learn from the history and prehistory 

these resources contain. With so many cultural resources entrusted in 

our care, the NPS provides leadership nationwide to their preservation 

and management in regards to climate change.

Cultural resources are irreplaceable indicators of the wide array of 

lifeways, ideas, beliefs, practices, and experiences that, over time, have 

led to the world we live in today. The NPS researches both the impacts 

of climate change on cultural resources as well as the many forms of information about human history and human-environment interactions 

they contain. The NPS works to adapt cultural resource stewardship, 

management, research, and interpretive practices to the challenges of 

climate change.

March 2013

At Dry Tortugas National Park, repair planning at Fort Jefferson must take 

into account projected sea level rise and increased storm intensity.

Climate Change Response Program National Park Service

U.S. Department of the Interior

Natural Resource Stewardship & Science

Cultural Resources, Partnerships & Science

Cultural Resources and Climate Change 

Background

Approach

More Information

Marcy Rockman, Ph.D.

Climate Change Adaptation ph: (202) 354-2105

Coordinator for Cultural Resources email: Marcy_Rockman@nps.gov 

Dan Odess

Chief ph: (202) 354-2128

Cultural Resources Science and Research email: Daniel_Odess@nps.gov

Cultural Resource Brief

 http://www.nps.gov/climatechange

Policy and Program Development

•	 Expansion of NPS Climate Change Response Strategy Goal 7 — 

Implement Cultural Resource Adaptation — into a comprehensive 

program plan that sets out the dual relationship of cultural resources and climate change – impacts on and information from. 

•	 Engagement of park, regional, and program staff in the “Climate 

and Culture” community of practice.

Science

•	 Development of a handbook outlining the types of impacts observed and anticipated from climate change to all categories of 

cultural resources across each eco-region of the nation. 

Current Projects

•	 Ongoing inventory and research of artifacts exposed by melting 

high mountain ice patches, known as “ice patch archaeology.” 

•	 Integration of natural and cultural data in assessments of resource 

vulnerability to projected climate change trends.

•	 Incorporation of cultural resources into scenario planning training 

and park planning documents.

•	 Training and guidance on cultural resources research priorities and 

planning at landscape and multi-agency scales for federal, state, 

tribal, and other partners.

Coastal Adaptation Handbook

•	 Development of management options for vulnerable cultural resources in the coastal zone and linking of the decision frameworks 

to those for adjacent natural resources and infrastructure.

Telling Climate Stories

•	 Cultural resources are an integral part of NPS climate change story. 

Developing instructional products on the progression of climate 

change and engaging with long-term and ongoing relationships between humans and our environments will help park staff more fully 

share these impacts and lessons learned with park visitors.

NPS published its Cultural Resources and 

Climate Change Policy in March 2013.

CREDIT: NPS

72 | CHAPTER 5—TOWARD A COMMON GOAL
implemented, will further improve the efficiency and effectiveness of agency stewardship 

of historic properties.

The federal government will face unprecedented challenges in the next three years as it 

continues its efforts to reduce the size of its real property inventory and ensure the energy 

efficiency, sustainability, and climate change adaptability of its remaining portfolio. The 

continued productive use of federal historic properties is a solution for energy efficient, 

sustainable, adaptable, and resilient real property needs. Further, investment in them 

promotes economic development and community pride. The ACHP will continue 

to work with agencies to fulfill these goals and meet its own mission to promote the 

preservation, enhancement, and sustainable use of the nation’s diverse historic resources, 

and advise the President and Congress on national historic preservation policy. The 

preservation of this irreplaceable heritage is in the public interest so that the cultural, 

educational, aesthetic, inspirational, and economic benefits will be maintained and 

enriched for future generations of Americans.

CHAPTER 5—TOWARD A COMMON GOAL | 73
APPE NDIX A : EXECU TIVE ORDER 

13287, PRESERVE AMERICA

By the authority vested in me as President by the Constitution and the laws of the 

United States of America, including the National Historic Preservation Act (16 U.S.C. 

470 et seq.) (NHPA) and the National Environmental Policy Act (42 U.S.C. 4321 et 

seq.), it is hereby ordered:

SECTION 1. STATEMENT OF POLICY. It is the policy of the Federal 

Government to provide leadership in preserving America’s heritage by actively advancing 

the protection, enhancement, and contemporary use of the historic properties owned 

by the Federal Government, and by promoting intergovernmental cooperation and 

partnerships for the preservation and use of historic properties. The federal government 

shall recognize and manage the historic properties in its ownership as assets that can 

support department and agency missions while contributing to the vitality and economic 

well-being of the nation’s communities and fostering a broader appreciation for the 

development of the United States and its underlying values. Where consistent with 

executive branch department and agency missions, governing law, applicable preservation 

standards, and where appropriate, executive branch departments and agencies (“agency” 

or “agencies”) shall advance this policy through the protection and continued use of the 

historic properties owned by the federal government, and by pursuing partnerships 

with state and local governments, Indian tribes, and the private sector to promote the 

preservation of the unique cultural heritage of communities and of the nation and to 

realize the economic benefit that these properties can provide. Agencies shall maximize 

efforts to integrate the policies, procedures, and practices of the NHPA and this order 

into their program activities in order to efficiently and effectively advance historic 

preservation objectives in the pursuit of their missions. 

SEC. 2. BUILDING PRESERVATION PARTNERSHIPS. When carrying 

out its mission activities, each agency, where consistent with its mission and 

governing authorities, and where appropriate, shall seek partnerships with State and 

local governments, Indian tribes, and the private sector to promote local economic 

development and vitality through the use of historic properties in a manner that 

contributes to the long-term preservation and productive use of those properties. Each 

agency shall examine its policies, procedures, and capabilities to ensure that its actions 

encourage, support, and foster public-private initiatives and investment in the use, reuse, 

and rehabilitation of historic properties, to the extent such support is not inconsistent 

with other provisions of law, the Secretary of the Interior’s Standards for Archeology 

and Historic Preservation, and essential national department and agency mission 

requirements.

SEC. 3. IMPROVING FEDERAL AGENCY PLANNING AND 

ACCOUNTABILITY.

(a) Accurate information on the state of Federally owned historic properties is essential 

to achieving the goals of this order and to promoting community economic development 

74 | APPENDIX A—EXECUTIVE ORDER 13287, PRESERVE AMERICA
through local partnerships. Each agency with real property management responsibilities 

shall prepare an assessment of the current status of its inventory of historic properties 

required by section 110(a)(2) of the NHPA (16 U.S.C. 470h-2(a)(2)), the general 

condition and management needs of such properties, and the steps underway or planned 

to meet those management needs. The assessment shall also include an evaluation of 

the suitability of the agency’s types of historic properties to contribute to community 

economic development initiatives, including heritage tourism, taking into account agency 

mission needs, public access considerations, and the long-term preservation of the historic 

properties. No later than September 30, 2004, each covered agency shall complete a 

report of the assessment and make it available to the Chairman of the Advisory Council 

on Historic Preservation (Council) and the Secretary of the Interior (Secretary). 

(b) No later than September 30, 2004, each agency with real property management 

responsibilities shall review its regulations, management policies, and operating 

procedures for compliance with sections 110 and 111 of the NHPA (16 U.S.C. 

470h-2 & 470h-3) and make the results of its review available to the Council and 

the Secretary. If the agency determines that its regulations, management policies, and 

operating procedures are not in compliance with those authorities, the agency shall make 

amendments or revisions to bring them into compliance. 

(c) Each agency with real property management responsibilities shall, by September 

30, 2005, and every third year thereafter, prepare a report on its progress in identifying, 

protecting, and using historic properties in its ownership and make the report available 

to the Council and the Secretary. The Council shall incorporate this data into a report on 

the state of the Federal Government’s historic properties and their contribution to local 

economic development and submit this report to the President by February 15, 2006, 

and every third year thereafter. 

(d) Agencies may use existing information gathering and reporting systems to fulfill the 

assessment and reporting requirements of subsections 3(a)-(c) of this order. To assist 

agencies, the Council, in consultation with the Secretary, shall, by September 30, 2003, 

prepare advisory guidelines for agencies to use at their discretion. 

(e) No later than June 30, 2003, the head of each agency shall designate a senior policy 

level official to have policy oversight responsibility for the agency’s historic preservation 

program and notify the Council and the Secretary of the designation. This senior official 

shall be an assistant secretary, deputy assistant secretary, or the equivalent, as appropriate 

to the agency organization. This official, or a subordinate employee reporting directly 

to the official, shall serve as the agency’s Federal Preservation Officer in accordance 

with section 110(c) of the NHPA. The senior official shall ensure that the Federal 

Preservation Officer is qualified consistent with guidelines established by the Secretary 

for that position and has access to adequate expertise and support to carry out the duties 

of the position. 

SEC. 4. IMPROVING FEDERAL STEWARDSHIP OF HISTORIC 

PROPERTIES. (a) Each agency shall ensure that the management of historic 

properties in its ownership is conducted in a manner that promotes the long-term 

preservation and use of those properties as Federal assets and, where consistent with 

APPENDIX A—EXECUTIVE ORDER 13287, PRESERVE AMERICA | 75
agency missions, governing law, and the nature of the properties, contributes to the local 

community and its economy. 

(b) Where consistent with agency missions and the Secretary of the Interior’s 

Standards for Archeology and Historic Preservation, and where appropriate, agencies 

shall cooperate with communities to increase opportunities for public benefit from, 

and access to, Federally owned historic properties. 

(c) The Council is directed to use its existing authority to encourage and accept donations of 

money, equipment, and other resources from public and private parties to assist other agencies 

in the preservation of historic properties in Federal ownership to fulfill the goals of the NHPA 

and this order. 

(d) The National Park Service, working with the Council and in consultation with other 

agencies, shall make available existing materials and information for education, training, 

and awareness of historic property stewardship to ensure that all Federal personnel have 

access to information and can develop the skills necessary to continue the productive use 

of Federally owned historic properties while meeting their stewardship responsibilities. 

(e) The Council, in consultation with the National Park Service and other agencies, 

shall encourage and recognize exceptional achievement by such agencies in meeting the 

goals of the NHPA and this order. By March 31, 2004, the Council shall submit to the 

President and the heads of agencies recommendations to further stimulate initiative, 

creativity, and efficiency in the Federal stewardship of historic properties.

SEC. 5. PROMOTING PRESERVATION THROUGH HERITAGE 

TOURISM. (a) To the extent permitted by law and within existing resources, the 

Secretary of Commerce, working with the Council and other agencies, shall assist 

States, Indian tribes, and local communities in promoting the use of historic properties 

for heritage tourism and related economic development in a manner that contributes 

to the long-term preservation and productive use of those properties. Such assistance 

shall include efforts to strengthen and improve heritage tourism activities throughout 

the country as they relate to Federally owned historic properties and significant natural 

assets on Federal lands.

(b) Where consistent with agency missions and governing law, and where appropriate, 

agencies shall use historic properties in their ownership in conjunction with State, tribal, 

and local tourism programs to foster viable economic partnerships, including, but not 

limited to, cooperation and coordination with tourism officials and others with interests 

in the properties.

SEC. 6. NATIONAL AND HOMELAND SECURITY CONSIDERATIONS. 

Nothing in this order shall be construed to require any agency to take any action 

or disclose any information that would conflict with or compromise national and 

homeland security goals, policies, programs, or activities.

SEC. 7. DEFINITIONS. For the purposes of this order, the term “historic property” 

means any prehistoric or historic district, site, building, structure, and object included 

on or eligible for inclusion on the National Register of Historic Places in accordance 

with section 301(5) of the NHPA (16 U.S.C. 470w(5)). The term “heritage tourism” 

76 | APPENDIX A—EXECUTIVE ORDER 13287, PRESERVE AMERICA
means the business and practice of attracting and accommodating visitors to a place or 

area based especially on the unique or special aspects of that locale’s history, landscape 

(including trail systems), and culture. The terms “Federally owned” and “in Federal 

ownership,” and similar terms, as used in this order, do not include properties acquired 

by agencies as a result of foreclosure or similar actions and that are held for a period of 

less than 5 years.

SEC. 8. JUDICIAL REVIEW. This order is intended only to improve the internal 

management of the Federal Government and it is not intended to, and does not, create 

any right or benefit, substantive or procedural, enforceable at law or equity by a party 

against the United States, its departments, agencies, instrumentalities or entities, its 

officers or employees, or any other person.

GEORGE W. BUSH 

THE WHITE HOUSE,

March 3, 2003.

At the time this EO was issued, the National Historic Preservation Act (NHPA) was codified at 16 

U.S.C. § 470 et seq. Effective December 19, 2014, the NHPA was moved to 54 U.S.C. § 300101 et 

seq. In accordance with Public Law 113-287 which authorized this change, a reference to an old title 

16 provision is legally deemed to refer to the corresponding provision in the new title 54 (e.g., for 

Section 106 of the NHPA, 16 U.S.C. § 470f refers to 54 U.S.C. 306108).

APPENDIX A—EXECUTIVE ORDER 13287, PRESERVE AMERICA | 77
APPE NDIX B : ADVISORY COU N CIL ON 

H I S TOR IC PR E SE RVAT IO N M E M BE R SH I P

Chairman

Milford Wayne Donaldson (California)

Vice Chairman

Vacant 

Expert Members

Terry Guen (Illinois) 

Dorothy Lippert (District of Columbia)

Lynne Sebastian (New Mexico) 

Robert G. Stanton (Virginia)

General Public

Teresa Isabel Leger de Fernandez (New Mexico)

Bradford J. White (Illinois) 

Member of an Indian Tribe or Native Hawaiian 

Organization

Leonard A. Forsman (Suquamish Tribe, Washington)

Governor

Vacant

Mayor

Hon. Joseph P. Riley Jr. (Charleston, South Carolina)

Architect of the Capitol

Secretary, Department of Agriculture

Secretary, Department of the Interior

Administrator, General Services Administration

Secretary, Department of Defense

Secretary, Department of Education

Secretary, Department of Homeland Security

Secretary, Department of Housing and Urban 

Development

Secretary, Department of Transportation

Secretary, Department of Veterans Affairs

Chair, National Trust for Historic Preservation

President, National Conference of State Historic 

Preservation Officers

Observer: General Chairman, National Association of 

Tribal Historic Preservation Officers

Observer: Secretary, Department of Energy

Observer: Administrator, Environmental Protection 

Agency

Observer: Chair, Council on Environmental Quality 

Observer: Chair, National Alliance of Preservation 

Commissions

Observer: President, ACHP Alumni Foundation

78 | APPENDIX B—ADVISORY COUNCIL ON HISTORIC PRESERVATION MEMBERSHIP
APPE NDIX C : AGE N CY SECTION 3 REP ORTS 

SUBMITTED, 2004–2014

AGENCY 2004 

baseline 

2005 

progress

2008 

progress 

2011 

progress 

2014 

progress 

Armed Forces Retirement Home (AFRH) ✔ ✔ ✔

Agriculture, Department of (USDA)

Agricultural Research Service (ARS) ✔

U.S. Forest Service (FS) ✔ ✔ ✔ ✔

Farm Services Agency (FSA) ✔ ✔

Natural Resources Conservation Service (NRCS) ■ ✔ ✔ ✸

Rural Development ✔ ✔ ✸ ✸

Commerce, Department of (DOC) ✔ ✔

National Oceanic and 

Atmospheric Administration (NOAA) ✔ ▲ ▲ ▲

Defense, Department of (DOD) ✔ ✔ ■

United States Army 

Corps of Engineers (COE) ✔ ✔

Education, Department of (ED) ✸ ✸ ✸ ✸

Energy, Department of (DOE) ✔ ✔ ✔ ✔

Environmental Protection Agency (EPA) ✔ ✔ ✔ ✔ ✔

Federal Energy 

Regulatory Commission (FERC) ✔ ✔

General Services Administration (GSA) ✔ ✔ ✔ ✔ ✔

Health and Human Services, Department of (HHS) ✔ ✔ ✔ ✔ ✔

Homeland Security, Department of (DHS) ✔ ✔ ✔ ✔ ✔

Federal Law Enforcement 

Training Center ✔ ▲ ▲ ▲

Housing and Urban Development, Department of 

(HUD) ✔

✔ Report filed by deadline September 30

■ Agency submitted draft or final progress report at time of production of the Report to the President.

✸ Agency notified the ACHP that the provisions of Section 3 of EO 13287 did not apply to them because they did not own real property.

▲ Agency notified the ACHP that they will no longer file individual agency progress reports, but their information will be included in their parent 

department/agency progress report.

APPENDIX C—AGENCY SECTION 3 REPORTS SUBMITTED, 2004–2014 | 79
AGENCY 2004 

baseline 

2005 

progress

2008 

progress 

2011 

progress 

2014 

progress 

Interior, Department of the (DOI)

Bureau of Indian Affairs (BIA) ✔ ✔ ✔ ✔ ✔

Bureau of Land Management (BLM) ✔ ✔ ✔ ✔ ■

Bureau of Reclamation (BOR) ✔ ✔ ✔ ✔

Fish and Wildlife Service (FWS) ✔ ✔ ✔ ✔ ✔

National Park Service (NPS) ✔ ✔ ✔ ✔ ■

United States Geological Survey (USGS) ✔ ✔ ■ ✔

Justice, Department of (DOJ) ✔ ✔ ✔ ■

Federal Bureau of Prisons (BOP) ✔ ✔ ▲ ▲ ✔

Labor, Department of (DOL) ✔ ✔ ✔ ✔

National Aeronautics and Space Administration 

(NASA) ✔ ✔ ✔ ✔ ✔

National Archives and Records Administration 

(NARA) ✔ ✔

National Science Foundation (NSF) ✸ ✸ ✸ ✸

Nuclear Regulatory Commission (NRC) ✸ ✸ ✸ ✸

Small Business Administration (SBA) ✸ ✸ ✸ ✸

State, Department of (DOS) ✔

Surface Transportation Board (STB) ✔

Tennessee Valley Authority ✔ ✔ ✔

Transportation, Department of (DOT)

Federal Aviation Administration (FAA) ✔ ✔ ✔ ✔ ✔

Federal Highway Administration (FHWA) ✔ ✸ ✸ ✸ ✸

Federal Motor Carrier 

Safety Administration (FMCSA) ✸ ✸ ✸ ✸ ✸

Federal Railroad Administration (FRA) ✸ ✸ ✸ ✸ ✸

Federal Transit Administration (FTA) ✸ ✸ ✸ ✸ ✸

Maritime Administration (MARAD) ✔ ✔ ✔ ✔

Treasury, Department of (TREAS) ✔ ✔ ✔ ✔

Bureau of Engraving and Printing (BEP) ✔ ✔

U.S. Postal Service (USPS) ✔ ✔ ✔ ■ ✔

Veterans Affairs, Department of (VA) ✔ ✔ ✔ ■ ✔

✔ Report filed by deadline September 30

■ Agency submitted draft or final progress report at time of production of the Report to the President.

✸ Agency notified the ACHP that the provisions of Section 3 of EO 13287 did not apply to them because they did not own real property.

▲ Agency notified the ACHP that they will no longer file individual agency progress reports, but their information will be included in their parent 

department/agency progress report.

80 | APPENDIX C—AGENCY SECTION 3 REPORTS SUBMITTED, 2004–2014
APPE N DI X D : ADV I S ORY 

GUIDELI NES I MPLE ME NTI N G 

SECTION 3: REP ORTI N G 

PRO GRESS ON THE 

I DE N T I F IC AT IO N, PROT E C T IO N, 

AND USE OF FEDER AL HIS TORIC 

PROPERTIES

Mandates on the management of federal real property continue to evolve and will 

continue to do so in the coming years as the federal government looks to reduce its size 

and carbon footprint. In response to these changes and trends, the ACHP issued revised 

guidelines in May 2014 to assist federal agencies in developing their progress reports. 

Specifically, the revised advisory guidelines augmented previous guidance by asking 

agencies to provide information regarding compliance with EO 13514, which has direct 

effects on historic properties within the federal real property inventory. It also requested 

additional information on agency preservation programs, with specific reference to their 

strategies for complying with Section 106 of NHPA. As in previous reporting, the use 

of these guidelines was not mandatory. A federal agency with real property management 

responsibilities could, at its discretion, determine how it would report on the progress of 

its efforts to identify, protect, and use its historic properties.

EO 13287 is not the only federal requirement for agencies to report on the status of 

their historic preservation programs. It is, however, one of the only federal reporting 

requirements that require an agency to assess historic properties as a whole and not 

simply by individual property type. An agency’s five-year strategic plan, as required by 5 

U.S.C. § 306, the annual performance plan, as required by 31 U.S.C. § 1115 (as amended 

by the Government Performance and Results Act of 1993), the development of annual 

Asset Management Plans as required by EO 13327, and the Statement of Federal 

Financial Accounting Standards 29: Heritage Assets and Stewardship Lands required by 

OMB are notable prior requirements. Newer requirements include the development of 

annual Strategic Sustainability Performance Plans as required by EO 13514. The ACHP 

acknowledged these multiple reporting requirements and provided guidance to agencies 

on how information developed for these other mandates could be used for reporting 

under Section 3.

The following questions were asked in the 2014 Advisory Guidelines:

1. Building upon previous Section 3 reports, please explain how many historic 

properties have been identified and evaluated by your agency in the past three 

years? Has your inventory improved? Please explain.

2. Describe your agency policies that promote and/or influence the identification 

and evaluation of historic properties.

APPENDIX D—ADVISORY GUIDELINES IMPLEMENTING SECTION 3 | 81
3. How has your agency established goals for the identification and evaluation of 

historic properties including whether they have been met?

4. Describe any internal reporting requirements your agency may have for the 

identification and evaluation of historic properties, including collections (museum 

and archaeological).

5. Explain how your agency has employed the use of partnerships to assist in the 

identification and evaluation of historic properties.

6. Provide specific examples of major challenges, successes, and or opportunities your 

agency has experienced in identifying historic properties over the past three years.

7. Explain how your agency has protected historic properties.

8. Describe the programs and procedures your agency has established to ensure the 

protection of historic properties, including compliance with Sections 106, 110, 

and 111 of NHPA. 

9. Describe your agency policies that promote and/or influence the protection of 

historic properties.

10. Explain how your agency has employed the use of partnerships to assist in the 

protection of historic properties.

11. Provide specific examples of major challenges, successes, and/or opportunities 

your agency has encountered in protecting historic properties over the past three 

years.

12. Explain how your agency has used historic properties.

13. Explain the overall condition of the historic properties within your agency’s 

control.

14. Describe your agency policies that promote and/or influence the use of its historic 

properties.

15. Explain how your agency has used Section 111 (16 U.S.C. § 470h-3) of NHPA 

in the protection of historic properties.

16. Explain how your agency has employed the use of partnerships to assist in the use 

of historic properties.

17. Provide specific examples of major challenges, successes, and/or opportunities 

your agency has encountered in using historic properties over the past three years.

18. Describe your agency’s sustainability goals and climate change adaptation 

planning and how stewardship of historic properties is being addressed.

82 | APPENDIX D—ADVISORY GUIDELINES IMPLEMENTING SECTION 3
APPE NDIX E : FEDER AL REAL 

PROPERTY REPORTING

Reporting 

Requirement Purpose

Submitted 

to Who should report Due Date

EO 13327: 

Federal Real 

Property Profile

This report is intended to promote 

efficient and economical use of real 

property resources, increase agency 

accountability and management attention 

to real property reform, and establish 

clear real property goals and objectives.

GSA Agencies listed in 

901(b)(1) and (b)(2) 

title 31; DHS

Annually, on 

December 

15

EO 13327: Asset 

Management 

Plan

Each agency will draft an asset 

management plan that addresses at a 

minimum, the Federal Real Property 

Council Guiding Principles and the 

required components

OMB Agencies listed in 

901(b)(1) and (b)(2) 

title 31; DHS

Annually, 

dependent 

upon the 

quarter 

OMB 

approved 

previous 

plan

SFFAS 29 

(Heritage Assets)

Disclosure requirements applicable 

to the agency financial statements 

and the U.S. Government-wide 

Financial Statement for heritage assets 

and stewardship land information 

reclassified as basic information with 

the exception of condition reporting, 

which is considered required 

supplementary information

Congress/

OMB

All federal agencies 

required to prepare 

audited financial 

statements under 

the Chief Financial 

Officer, Government 

Management Reform, 

and Accountability of 

Tax Dollars Acts

Annually, 45 

days after 

the end of 

the fiscal 

year

The Report to 

Congress on 

the Federal 

Archaeology 

Program

To report on federal archaeological 

activities in order to offer assistance 

with professional methods for 

archaeological preservation and for the 

administration of historic preservation 

programs

NPS All federal agencies 

and departments that 

undertake, contract 

for, issue permits 

and licenses, or that 

require archaeological 

investigations of other 

parties

Annually, on 

May 1

EO 13287: 

Section 3(c) 

Progress 

Reporting

Prepare a report on an agency’s 

progress in identifying, protecting, and 

using historic properties in its ownership 

and make the report available to the 

ACHP and the Secretary of the Interior

ACHP All federal agencies 

with real property 

management 

responsibilities

Triennially, 

beginning 

September 

2005

EO 13514: 

Strategic 

Sustainability 

Performance 

Plan and Annual 

Updates

Prepare a strategic sustainability 

performance plan to prioritize agency 

actions based on lifecycle return on 

investment

OMB/CEQ All federal agencies 

defined in Section 

105 of Title 5, United 

States Code, excluding 

the Government 

Accountability Office

Annually, 

beginning 

June 2010

APPENDIX E—FEDERAL REAL PROPERTY REPORTING | 83
ADVISORY COUNCIL ON HISTORIC PRESERVATION

401 F STREET NW, SUITE 308

WASHINGTON, DC 20001-2637

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Preserving America’s Heritage