A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT

THE PRESERVE AMERICA EXECUTIVE ORDER REPORT TO THE PRESIDENT

February 15, 2012
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

1100 Pennsylvania Avenue, NW

Suite 803

Washington, DC 20004

Phone: 202-606-8503

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

Front cover photography (left to right): Fort Monroe Authority, NPS, ACHP

Preserving America’s Heritage
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TABLE OF CONTENTS

ACKNOWLEDGEMENTS................................................................................................................................................... v

ACRONYMS AND ABBREVIATIONS.............................................................................................................................. vi

CHAIRMAN’S MESSAGE................................................................................................................................................... vii

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

EXECUTIVE SUMMARY....................................................................................................................................................... x

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

History of Executive Order No. 13287..........................................................................................................................................................12

Preserve America........................................................................................................................................................................................................14

Previous Section 3 Reporting...............................................................................................................................................................................14

Framework for 2012 Report to the President...........................................................................................................................................21

CHAPTER 2: CURRENT STATE OF FEDERAL REAL PROPERTY MANAGEMENT..........................................22

American Recovery and Reinvestment Act (2009).................................................................................................................................23

Executive Order No. 13514, “Federal Leadership in Environmental, Energy, and Economic 

Performance” (2009).................................................................................................................................................................................................23

Issuance of Presidential Memorandum—America’s Great Outdoors (2010).........................................................................23

Issuance of Presidential Memorandum—Disposing of Unneeded Federal Real Estate (2010).....................................26

Issuance of Presidential Memorandum—Speeding Infrastructure Development through More 

Efficient and Effective Permitting and Environmental Review (2011)............................................................................................29

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

CHAPTER 3: CURRENT STATE OF FEDERAL STEWARDSHIP .............................................................................33

Contributing to the Economy ..............................................................................................................................................................................34

Recreation and Tourism............................................................................................................................................................................................35

Cooperative Management and Use..................................................................................................................................................................39

Community Revitalization.......................................................................................................................................................................................42

Building Partnerships.................................................................................................................................................................................................44

Managing Assets...........................................................................................................................................................................................................46

Integrating Stewardship into Agency Planning ............................................................................................................................................51

Enhancing and Improving Inventories of Historic Properties.............................................................................................................58

Summary ..........................................................................................................................................................................................................................62
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CHAPTER 4: FINDINGS AND RECOMMENDATIONS............................................................................................63

FINDING No. 1: Economic Development and Job Creation.............................................................................................................64

FINDING No. 2: Sustainability..............................................................................................................................................................................66

FINDING No. 3: Renewable Energy.................................................................................................................................................................68

FINDING No. 4: Federal Real Property Realignment ............................................................................................................................70

FINDING No. 5: Federal Agency Preservation Programs in the 21st Century.......................................................................73

Summary ..........................................................................................................................................................................................................................75

CHAPTER 5: TOWARD A COMMON GOAL .............................................................................................................76

CASE STUDIES

Section 106 Program Alternatives Streamline Agency Review and Compliance ...................................................................16

The National Park Service and Sustainability—At the Forefront of Assisting Federal Agencies...................................19

Advisory Council on Historic Preservation’s Contributions to Implementation of EO 13514.....................................24

Job Creation Through Recovery Act Funding..............................................................................................................................................27

America’s Great Outdoors and Historic Resource Stewardship.....................................................................................................30

Sesquicentennial of the American Civil War (2009-2015)..................................................................................................................37

Leasing of Historic Properties in National Park System Units..........................................................................................................41

General Services Administration Reinvests Strategically to Sustain a Public Building Legacy..........................................47

Bureau of Land Management’s Renewable Energy Efforts..................................................................................................................53

Closure of Fort Monroe, Virginia and Creation of a New National Monument....................................................................61

Preservation Green Lab: A Nonprofit’s Contribution to Sustainable Development............................................................78

APPENDIX A: EXECUTIVE ORDER 13287, PRESERVE AMERICA..........................................................................80

APPENDIX B: ADVISORY COUNCIL ON HISTORIC PRESERVATION MEMBERSHIP....................................83

APPENDIX C: ADVISORY GUIDELINES IMPLEMENTING SECTION 3: 

REPORTING PROGRESS ON THE IDENTIFICATION, PROTECTION, AND USE OF 

FEDERAL HISTORIC PROPERTIES .................................................................................................................................84

APPENDIX D: EXECUTIVE BRANCH AGENCIES’ COMPLIANCE WITH EO 13287......................................86

APPENDIX E: FEDERAL REAL PROPERTY REPORTING .........................................................................................88
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ACKNOWLEDGEMENTS

The Advisory Council on Historic Preservation (ACHP) wishes to extend its 

appreciation and thanks to the following individuals and organizations for their 

time and contribution in assisting the ACHP to implement the provisions of 

Section 3 of Executive Order 13287:

FEDERAL AGENCY PROGRAMS COMMITTEE

Mark Sadd, Committee Chairman

Horace Foxall, Jr., Committee Vice Chairman

John L. Berrey

Dorothy Lippert

National Trust for Historic Preservation

Department of Defense

Department of Transportation

Department of Veterans Affairs

General Services Administration

Department of Homeland Security, Observer

National Association of Tribal Historic Preservation Officers, 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 

(report co-author)

Katharine R. Kerr, Program Analyst (report co-author)

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

Ronald D. Anzalone, Director, Office of Preservation Initiatives

Shayla Shrieves, Senior Writer-Editor

Druscilla J. Null, Senior Program Analyst

DEPARTMENT OF THE INTERIOR

Stephanie Toothman, Associate Director for Cultural Resources, National Park Service
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ACRONYMS AND ABBREVIATIONS

ACHP Advisory Council on Historic Preservation

ATDA Accountability of Tax Dollars Act

AGO America’s Great Outdoors

Army Department of the Army

ARNG Army National Guard

AMP Asset Management Plan

BLM Bureau of Land Management

BIA Bureau of Indian Affairs

BOR Bureau of Reclamation

C&O Chesapeake & Ohio Canal

CFO Chief Financial Officer

C.F.R. Code of Federal Regulations

CEQ Council on Environmental Quality

CBP Customs and Border Protection

CPRA Civilian Property Realignment Act

CRMP Cultural Resources Management Plan

DOC Department of Commerce

DOE Department of Energy

DHS Department of Homeland Security

DOI Department of the Interior

DOJ Department of Justice

DOT Department of Transportation

EISA Energy Independence and Security Act of 2007

EPA Environmental Protection Agency

EO Executive Order

FPO Federal Preservation Officer

FPMS Federal Property Management Section

FRPC Federal Real Property Council

FRPP Federal Real Property Profile

FAIA Fellow, American Institute of Architects

FY Fiscal Year

FS Forest Service

FSM Forest Service Manual

FMA Fort Monroe Authority

GSA General Services Administration

GMRA Government Management Reform Act

HHS Department of Health and Human Services

HAP Heritage Assets Partnership

LEED Leadership in Energy and Environmental Design

Legacy Vision Integration of a Federal Legacy Vision with 

GSA’s Portfolio Strategy for Restructuring and 

Reinvesting in the Owned-Inventory

MARAD Maritime Administration

MCHVF Montessori Children’s House of Valley Forge

NASA National Aeronautics and Space Administration

NPD NASA Policy Directive

NPR NASA Procedural Requirement

NCSHPO National Conference of State Historic 

Preservation Officers

NEPA National Environmental Policy Act

NGB National Guard Bureau

NHL National Historic Landmark

NHPA National Historic Preservation Act of 1966 as 

amended

NOAA National Oceanic and Atmospheric 

Administration

NPS National Park Service

NRHP National Register of Historic Places

NTHP National Trust for Historic Preservation

NHO Native Hawaiian organization

OMB Office of Management and Budget

PGL Preservation Green Laboratory

PA Programmatic Agreement

RPAC Real Property Advisory Committee

Recovery Act American Recovery and Reinvestment Act

SPDP St. Petersburg Downtown Partnership

SPO Senior Policy Official

SSO Senior Sustainability Officer

SRPO Senior Real Property Officer

SEZ Solar Energy Zones

SHPO State Historic Preservation Officer

SFFAS Statement of Federal Financial Accounting 

Standards

SSPP Strategic Sustainability Performance Plan

TVA Tennessee Valley Authority

Treasury Department of Treasury

U.S. United States

USACE United States Army Corps of Engineers

USCG United States Coast Guard

U.S.C. United States Code

USFWS United States Fish and Wildlife Service

USGS United States Geological Survey

USP United States Penitentiary

USPS United States Postal Service

VCP Veterans Curation Project

WREHPWG Western Renewable Energy and Historic 

Preservation Workgroup
MILFORD WAYNE 

DONALDSON, FAIA

Chairman, Advisory Council 

on Historic Preservation

February 15, 2012

FRONT MATTER | vii

CHAIRMAN’S MESSAGE

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

Council on Historic Preservation (ACHP) is pleased to present its third triennial 

report on how well federal agencies manage the historic properties they hold in 

stewardship for the American people. Federal agencies provided progress reports 

to the ACHP in 2011, which have been summarized in this report. Based on these 

submissions, the ACHP has developed a series of recommendations to advance 

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

The Preserve America Executive Order requires federal agencies to provide 

leadership in the management of historic properties. Advancing stewardship goals 

is a wise investment in sustainability and creating a strong economy. The federal 

government faces unprecedented challenges as it works to reduce the size of its 

real property inventory, transform buildings into energy efficient assets, and use 

these assets to promote economic development and create jobs. The retention of 

historic properties as energy efficient and strong performing assets can contribute 

to these goals and, in so doing, enhance community pride. 

Through a variety of agency activities and collaborative ventures, federally owned 

historic properties promote economic development and heritage tourism locally 

and regionally. For example, the National Park Service progress report indicated 

that visitors to its national parks contributed more than $14.2 billion to nearby 

communities in 2009, and the National Aeronautics and Space Administration 

reports that Kennedy Space Center in Florida, a place of unparalleled historic 

significance, attracts 1.5 million visitors annually. With the recent designation by 

the President of Fort Monroe National Monument, it is anticipated that nearly 

3,000 jobs will be created in the region. These statistics point to the role historic 

preservation plays in our economy, and the Administration’s success in using it as a 

tool for economic growth.

Many federal historic properties are located in Preserve America Communities, 

which obtain White House recognition for their commitment to protect and use 

their heritage assets. We are delighted that the First Lady has designated 136 such 

communities since January 2009, bringing the total to 872 nationwide. Through 

local partnerships, federal agencies support the preservation and economic 

development goals of these places important to so many across the country.

This report lays out specific projects and properties and the successes and 

challenges agencies face in ensuring proper use and potential re-use of the millions 

of square feet of historic property in federal hands. By considering the ACHP’s 

CONTINUED >>>
viii | FRONT MATTER

recommendations stemming from its thoughtful consideration of agency reports, 

such as encouraging partnerships and utilizing energy efficiency initiatives, agency 

heads and others will better understand the importance of the federal historic 

property inventory. Awareness of and appreciation for the value of these priceless 

resources under federal ownership can foster better management practices that 

will benefit agencies, the American people, and the historic properties themselves.

The ACHP supports Administration and agency initiatives to transform the federal 

government into a cost efficient, effective, and sustainable entity. We continue to 

encourage the Administration’s leadership and interest in historic preservation and 

appreciate the attention given to this important report.
SECRETARY OF THE 

INTERIOR’S MESSAGE

“In a spirit of stewardship” is the fundamental principle that defines the National 

Historic Preservation Program. For over a century, the Department of the Interior 

has provided leadership that sets the standard for recognizing, documenting, and 

preserving American history for future generations. Executive Order 13287, 

“Preserve America,” establishes Federal policy in preserving America’s heritage by 

actively advancing the protection, enhancement, and contemporary use of the 

historic properties owned by the Federal Government.

As Secretary of the Interior, I am charged with issuing, with the assistance of 

the National Park Service, a series of standards and guidelines setting forth 

best practices for a variety of preservation disciplines and activities. In 1998, 

the Department issued “Standards and Guidelines for Federal Agency Historic 

Preservation Programs Pursuant to the National Historic Preservation Act,” which 

describe how Federal agencies can balance their agency missions with their historic 

property stewardship mandates.

I am committed to engaging our Federal, state, tribal, and local partners in the 

preservation of our shared heritage. Our recent initiatives pay tribute to the 

importance of historic preservation. The President’s America’s Great Outdoors

initiative calls for the creation of new historic trails, parks, and landmarks and 

enhances support through the Historic Preservation Fund. The National Park 

Service’s A Call to Action paves the way to ensure that the Secretary’s Standards 

and Guidelines reflect 21st century preservation needs. Through the American 

Latino Heritage Initiative, we are supporting agency efforts to document Latino 

cultural resources. New departmental tribal consultation policies work to 

identify cultural resource concerns as we pursue new sources of energy to 

support our future growth. As we approach the 50th anniversary of the National 

Historic Preservation Act in 2016, I am confident that we will continue to 

successfully provide leadership and be effective stewards for the National Historic 

Preservation Program.

KEN SALAZAR

Secretary, Department of 

the Interior

February 15, 2012

FRONT MATTER | ix
EXECUTIVE SUMMARY

THIS IS THE THIRD TRIENNIAL REPORT to the President required 

under Executive Order 13287: “Preserve America,” addressing the state of 

the federal government’s historic properties and their contribution to local 

economic development. Issued in 2003, EO 13287 reaffirmed the federal 

government’s responsibility to show 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.”

Information in this document came primarily from the progress reports 

submitted to the Advisory Council on Historic Preservation (ACHP) in 

September 2011 by real property managing agencies within the executive 

branch, as well as stewardship meetings with policy and preservation officials 

committed to the stewardship of these important properties. Agency reports 

focused on progress made in identifying, protecting, and using historic properties 

in their ownership. Federal agencies continue to provide creative examples 

of how they have leased federal historic properties, creatively used others, 

established public-private partnerships, and supported heritage tourism 

programs and local economic development.

The ACHP reviewed these Section 3 progress reports to measure the critical 

progress federal agencies have made in the last three years. The ACHP is pleased 

to report that 24 agencies submitted reports on or after the September 30, 

2011, deadline.

In assessing the progress federal agencies have made over the last three 

years, the ACHP has made five key findings about the current state of federal 

historic property stewardship along with recommendations on how agencies 

Kaneohe Naval Air Station National Historic Landmark, Marine Corps Base Hawaii, Kaneohe Bay, Island of O’ahu, Hawaii

x | FRONT MATTER
CREDIT: ACHP

can continue to improve their performance in these areas. These findings are 

summarized as follows:

» While federal agencies and the historic properties under their ownership or control 

have great potential to create private sector jobs, contribute to the local economy, 

create public-private partnerships, improve property management practices, 

and contribute to local and regional heritage tourism initiatives, they have not 

systematically done so.

» Agencies would benefit from guidance on the advantages of retaining and 

converting historic buildings and structures into sustainable properties that meet 

the Administration’s goals for energy efficiency, as well as guidance on promoting 

the development of a sustainable federal infrastructure that recognizes the 

economic and environmental value of retaining historic properties.

» Renewable energy initiatives present opportunities for the preservation 

community to think creatively about resource stewardship and management in 

the current economic climate but also have the potential to significantly impact 

historic properties.

» Agencies face a significant challenge in the realignment of real property portfolios, 

balancing stewardship responsibilities and mission needs.

» 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 at the appropriate level. 

As a result, many agencies experience conflicts between the National Historic 

Preservation Act, other statutory requirements, and Administration initiatives.

The recommendations accompanying the findings in Chapter 4 offer a range of 

actions for the ACHP and its partners to further the current Administration initiatives 

and policies, goals of EO 13287, and NHPA related to real property management. 

The ACHP is committed to assisting federal agencies in moving forward with these 

recommendations so that future actions proposed by the Administration, and agencies 

themselves, recognize historic properties as important public assets worthy of full 

consideration in federal property management in a clean energy economy.

FRONT MATTER | xi
CHAPTER 1: INTRODUCTION AND 

BACKGROUND

FEDERAL HISTORIC PROPERTIES range from a nuclear merchant 

ship to shipwrecks, post offices to land ports of entry, office buildings to barns, 

and expansive archaeological sites to remote Native American sacred sites. 

Agencies own, acquire, and manage these diverse properties through a variety 

of programs and have developed wide ranging internal protocols for their 

inventory and stewardship.

HISTORY OF EXECUTIVE ORDER NO. 13287

EO 13287, “Preserve America,” directs federal agencies to recognize that historic 

properties owned by the federal government are valuable assets that support 

agency missions and also stimulate local economic development. Agencies 

approach the oversight and management of historic properties differently, based 

on budgetary, program, and management considerations unique to each agency. 

While many have made the preservation and protection of historic properties a 

priority, others face daunting challenges given the sheer volume and condition of 

their historic property inventory and competing mandates.

The policy set forth in Section 1 of EO 13287 reaffirms major principles of 

NHPA, as amended, by recognizing that federal agencies should manage federal 

St. George Island, Alaska, is 

one of five Pribilof Islands 

located 300 miles west of 

the Alaskan coast. The Native 

Aleut (Unangan) community 

shares stewardship of the 

island and its historic fur seal 

and sea bird resources with 

the National Marine Fisheries 

Service and the U.S. Fish and 

Wildlife Service. St. George 

Island was designated a 

Preserve America Community 

in 2007. 

CREDIT: NOAA
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.” 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 that the department or agency 

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

use of historic properties.

Section 3 of the EO established an accountability system to gauge agency 

implementation of the mandates of NHPA and the EO. It requires the ACHP to 

prepare a report to the President on the current state of the federal government’s 

historic properties and their contribution to local economic development. The 

ACHP’s report is to incorporate data submitted by real property managing 

agencies in accordance with Sections 3(a), (b), and (c) of the EO.

Section 4 of the EO requires each 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.

As required by Section 4(e), in March 2004 the ACHP submitted to the President 

and the heads of agencies a report titled Becoming Better Stewards of Our Past: 

Recommendations for Enhancing Federal Management of Historic Properties. This 

report provided recommendations to (1) partner with non-federal parties, (2) 

work smart, and (3) enhance the preservation ethic in order to further stimulate 

initiative, creativity, and efficiency in the federal stewardship of historic properties.

Promoting preservation through heritage tourism is specifically called for in 

Section 5 of the EO. As a primary goal of the Preserve America program, federal 

agencies were encouraged to support community efforts to preserve and 

enjoy the nation’s priceless cultural and natural heritage by 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. By working with states, Indian tribes, and local communities, 

agencies can use historic properties in their ownership to foster viable economic 

partnerships in cooperation with tourism officials and others with interests in the 

properties.

In order to better fulfill their stewardship responsibilities, agencies are directed 

to consider historic properties as assets that must be cared for in a manner that 

reflects the broader public interest. To that end, EO 13287 requires agencies to 

explore partnerships for sustaining the long-term preservation and productive use 

of such properties. Specifically, the EO, which applies to executive branch agencies 

and departments, encourages agencies to foster viable partnerships with tribal, 

state, and local heritage tourism programs for the use of historic properties.

CHAPTER 1—INTRODUCTION AND BACKGROUND | 13
PRESERVE AMERICA

In 2003, the Administration established Preserve America. Participating agencies 

include the ACHP, the Departments of Agriculture, Commerce, Defense, Education, 

Housing and Urban Development, Interior, and Transportation; the General 

Services Administration; the Institute of Museum and Library Services; the National 

Endowment for the Humanities; the President’s Committee on the Arts and the 

Humanities; and the President’s Council on Environmental Quality. Executive branch 

activities, and the federal reporting that corresponds to this EO, form an integral 

part of the program. The program also encourages and supports community efforts 

to preserve and enjoy our priceless cultural and natural heritage. Goals include a 

greater shared knowledge about the nation’s past, strengthened regional identities 

and local pride, increased local participation in preserving the country’s cultural and 

natural heritage assets, and support for the economic vitality of our communities.

Two facets of the Preserve America program are Preserve America Communities 

and Preserve America Stewards. 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 resources through education and heritage tourism programs. 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) tribal communities (federally recognized) 

with an elected governing official or subdivisions of such tribes. Preserve 

America Stewards is a designation program that recognizes programs that have 

demonstrated a successful use of volunteer time and commitment in order to help 

care for our historic heritage. Designation recognizes programs of organizations 

and 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 heritage 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.

PREVIOUS SECTION 3 REPORTING

The ACHP has continually acknowledged that the state of federal historic property 

management is improving but still in need of greater agency commitment and 

Administration oversight. While many federal agencies reported that they needed 

more funding to meet these responsibilities, the ACHP’s 2009 Report to the 

President emphasized the federal government’s need to develop a preservation 

ethic that considered the preservation and use of agency historic properties from 

the broader perspective of public benefits. The report also highlighted several 

areas anticipated to have an effect on real property management: sustainability, 

energy efficiency, and inventory reduction. Accordingly, the findings and 

recommendations outlined in the report were intended to assist agencies in taking 

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 resources 

through education 

and heritage tourism 

programs.

14 | CHAPTER 1—INTRODUCTION AND BACKGROUND
appropriate measures to meet their stewardship obligations, while recognizing the 

potential for their historic properties to be a catalyst for community development.

The ACHP identified six major findings in the 2009 Report to the President. 

The recommendations accompanying the findings offered a range of actions 

for federal property management agencies to consider. Many federal agencies 

had made real progress in identifying historic properties and reporting on their 

condition. However, many agencies confronted by multiple federal reporting 

requirements continued to provide incomplete progress reports, used and 

defined terminology describing their historic property inventory differently, and 

struggled to provide comprehensive and complete information in their inventory. 

The ACHP recommended that the federal agencies with real property support 

the development of comprehensive historic property inventories using existing 

reporting requirements, and noted there was continued improvement in agencies’ 

identification of historic properties. This has been confirmed in the 2011 agency 

progress reports.

It was noted that agencies would benefit from guidance on how to consider the 

advantages of retaining and converting historic buildings and structures into better 

energy performers, as well as guidance on how to promote the development of a 

sustainable federal infrastructure that recognizes the economical and environmental 

value of retaining historic properties. The ACHP encouraged the Administration 

to launch an initiative to maximize the economic and energy efficiency of federally 

owned historic buildings. EO 13514, “Federal Leadership in Environmental, Energy, 

and Economic Performance” (2009), establishes the President’s commitment 

to confront dependence on foreign oil; addressing the moral, economic, and 

environmental challenge of global climate change; and building a clean energy future 

that benefits all Americans. The ACHP issued guidance integrating the requirements 

of NHPA with Section 2(g) of EO 13514, requiring federal agencies to implement 

high performance federal building design, construction, operation and management, 

maintenance, and deconstruction. With the support of CEQ, the ACHP developed 

the guidance to assist federal agencies in their efforts to meet the expectations 

of EO 13514 and its Guiding Principles. In addition, this guidance addressed the 

intersection of historic preservation policy with the recommendations of the 

Department of Transportation and other federal agencies for selecting sustainable 

locations for federal facilities, prepared pursuant to Section 10 of the EO. The goal 

of this guidance was to assist federal decision makers, usually capital asset managers, 

facility managers, and other program and project managers, in their considerations 

regarding sustainability and historic federal buildings.

Federal agencies that own legacy buildings and other iconic and monumental 

historic buildings and structures were not receiving adequate reinvestment funding 

to conduct needed repairs and alterations to keep these properties occupied 

and viable. The ACHP advocated for federal agencies’ improved flexibility in 

using public-private partnerships through Section 412 of General Provisions, 

Consolidated Appropriations Act, Section 111 of NHPA, enhanced use leases, 

and similar authorities, consistent with agency mission and governing laws, for the 

The ACHP issued 

guidance integrating 

the requirements of 

NHPA with Section 

2(g) of EO 13514, 

requiring federal 

agencies to implement 

high performance 

federal building design, 

construction, operation 

and management, 

maintenance, and 

deconstruction.

CHAPTER 1—INTRODUCTION AND BACKGROUND | 15
Section 800.14 of the Advisory Council on 

Historic Preservation’s (ACHP) regulations 

lays out a variety of methods available to 

federal agencies to meet their Section 106 

obligations under the National Historic 

Preservation Act. Each of these program 

alternatives allows federal agencies to tailor 

the Section 106 process to meet their needs. 

In the past three years, the ACHP has 

worked with a number of federal agencies 

to develop program alternatives. Three of 

those are highlighted here.

General Services 

Administration: Program 

Comment for Select Envelope 

and Infrastructure Repairs and 

Upgrades to Historic Public 

Buildings

In August 2009, the ACHP issued a 

Program Comment for the General Services 

Administration, setting forth the way in 

which GSA will comply with Section 106 

for select repairs and upgrades to windows; 

lighting; roofing; and heating, ventilating, 

and air conditioning systems within historic 

public buildings. The Program Comment 

streamlines select review protocols for GSA, 

facilitating their execution of repair and 

upgrade projects that were funded by the 

American Recovery and Reinvestment Act 

and other sources.

Projects reviewed via the Program 

Comment must not adversely affect the 

qualities that qualify a historic property 

for the National Register of Historic 

Places. The projects must also be designed 

by qualified preservation architects 

who meet the Secretary of the Interior’s 

Professional Qualification Standards, 

and follow GSA’s Technical Preservation 

Guidelines; these guidelines were 

determined by the National Park Service 

to be consistent with the Secretary of the 

Interior’s Standards for Rehabilitation 

and Guidelines for Rehabilitating Historic 

Buildings. Work involving historic 

materials is executed by qualified firms 

specializing in the repair and restoration of 

historic buildings, under the supervision 

of GSA preservation staff who also meet 

the Secretary of the Interior’s Professional 

Qualification Standards.

The Program Comment is the result of 

consultation among GSA, the ACHP, NPS, 

the National Conference of State Historic 

Preservation Officers, the National Trust 

for Historic Preservation, the National 

Alliance of Preservation Commissions, and 

the National Association of Tribal Historic 

Preservation Officers.

National Guard Bureau: 

Nationwide Programmatic 

Agreement for Army National 

Guard Readiness Centers 

Maintenance and Repair

In December 2010, a nationwide 

Programmatic Agreement among the 

National Guard Bureau, NCSHPO, 

and the ACHP was executed regarding 

maintenance and repair projects for all 

The exterior windows of the Gerald W. Heaney Federal Building, U.S. Courthouse and Custom 

House, Duluth, Minnesota, were replaced in compliance with a streamlined Section 106 

program alternative in 2009.

CASE STUDY

Section 106 

Program 

Alternatives 

Streamline Agency 

Review and 

Compliance

FEDERAL AGENCY 

Advisory Council on Historic 

Preservation 

LOCATION 

Nationwide

CREDIT: GSA

16 | CHAPTER 1—INTRODUCTION AND BACKGROUND
federally owned or federally supported 

readiness centers in all 50 states, Puerto 

Rico, the U.S. Virgin Islands, Guam, 

and the District of Columbia. Routine 

maintenance is defined as regular and 

general upkeep of a readiness center 

against normal wear and tear above ground. 

The PA does not address undertakings 

that could cause ground disturbance or 

that may affect archaeological sites, except 

those areas previously designated by an 

easement (e.g., natural gas lines) or areas 

where disturbance has already occurred 

(e.g., sidewalks) for the first six inches 

depth of ground disturbance. The PA also 

does not apply to replacement or repair of 

wall insulation.

An individual state Army National 

Guard Cultural Resources Manager is 

responsible for determining whether a 

proposed activity meets the definition of 

an exempted undertaking under the PA. If 

the proposed activity meets one or more 

of the definitions it is exempted from 

further Section 106 review. The definitions 

include exterior and interior activities such 

as painting on previously painted surfaces 

using similar color and non-destructive 

lead paint abatement. If the proposed 

activity is not exempted there is a process 

stipulated for an individual state ARNG 

to follow for both no adverse effect and 

adverse effect determinations.

The decision to implement this PA must 

be made voluntary for state ARNGs, in 

consultation with their State Historic 

Preservation Officer. As of December 2011, 

19 individual state ARNGs have elected to 

implement the PA. The Nationwide PA is 

a result of consultation among NGB, the 

ACHP, NCSHPO, NPS, Department of 

the Army, NTHP, and cultural resources 

experts in academia.

The Department of the Army: 

Prototype Programmatic 

Agreement for Army Interiors

In July 2011, the ACHP issued a prototype 

PA to streamline the consideration of 

non-contributing interiors of buildings 

on Army installations that contribute 

to a historic district that is listed in or 

eligible for the NRHP and for buildings 

that are individually listed in or eligible 

for the NRHP; if an Army installation 

executed this prototype PA with a SHPO 

there would be no case-by-case review for 

those aspects of undertakings that may 

affect non-contributing interiors. The 

Army is steward of more than 20,000 

buildings considered eligible for the 

NRHP. A number of Army initiatives and 

Executive Orders have been implemented 

that require installations to improve the 

energy efficiency and sustainability of 

their facilities. These initiatives have the 

potential to impact interiors of eligible 

buildings; therefore this programmatic 

approach will assist in the protection of 

historic interiors while meeting Army and 

Administration goals.

The Army is now authorized to convey 

this prototype PA to its installations 

and develop agreements with individual 

SHPOs where they are deemed necessary 

and appropriate. These agreements can be 

negotiated between an installation and a 

SHPO without the involvement or approval 

of the ACHP. The prototype PA is a result 

of consultation among the Army, the ACHP, 

NPS, NCSHPO, and NTHP.

CHAPTER 1—INTRODUCTION AND BACKGROUND | 17
preservation and use of these and other federally owned and controlled historic 

buildings and structures.

The fourth finding made was that senior policymakers had not addressed historic 

property management needs or established goals for improvement in agency 

strategic plans to support an agency’s mission. The ACHP urged the Office of 

Management and Budget, in coordination with the Secretary of the Interior, to 

ensure that Senior Policy Officials are designated by all agencies in accordance with 

EO 13287 Section 3(e) and requested that agencies report to the ACHP, OMB, 

and the Secretary of the Interior once this designation had been made within one 

year of the 2009 report. In August 2009, the ACHP reiterated this requirement 

to agencies and requested such a designation during the Administration transition. 

The ACHP received responses from 32 departments and agencies.

In addition to the information federal agencies provided in progress reports, the 

ACHP identified several issues that clearly would have broad effects on property 

managing agencies in the coming years. One of those issues was the lack of 

strategies for evaluating modern-era buildings that would soon reach 50 years 

of age. The ACHP encouraged agencies to develop plans to identify and evaluate 

common property types in their portfolio and establish agency-wide management 

priorities for their consideration and use, and several agencies reported progress 

in the completion of such identification efforts and the establishment of 

management plans for those property types. The ACHP also encouraged agencies 

to establish procedures to identify historic properties or property types that may 

have value to state, tribal, or local communities for reuse or heritage tourism and 

ensure that these values are scored, using the National Register of Historic Places 

and the National Historic Landmark information, and considered prior to agency 

decisions on disposal of such properties. Based upon the 2011 progress reports, a 

number of agencies reported progress in that area.

And lastly, while federal agencies and the historic properties under their 

ownership or control have tremendous potential to contribute to local economic 

development through job creation, public-private partnerships, property 

management practices, and participation in local and regional heritage tourism 

initiatives, they have not systematically done so. The ACHP sought to compile 

and disseminate information and guidance on the economic value of federal 

historic property stewardship, with the potential of federal historic property 

contribution to local economic development, and integrate such material in 

future Section 3 advisory guidelines for agency use. To further this goal, the ACHP 

updated its advisory guidelines in 2011 with additional questions regarding agency 

compliance with EO 13514 and use of Sections 106, 110, and 111 of NHPA. In 

collaboration with the ACHP and other federal, state, tribal, and private partners, 

the Department of Commerce was encouraged to devise a uniform set of 

generally accepted metrics for measuring the direct and indirect economic impacts 

of historic properties at the state, regional, and local levels that could be applied 

nationally. The ACHP continues to advance this concept.

18 | CHAPTER 1—INTRODUCTION AND BACKGROUND
A commonly quoted phrase, “the greenest 

building is the one that’s already built,” 

succinctly expresses the relationship 

between preservation and sustainability. 

The repair and retrofitting of existing 

and historic buildings is considered by 

many to be the ultimate recycling project, 

and focusing on historic buildings has 

added benefits for the larger community. 

Traditional materials are generally 

durable, the continued maintenance of 

historic buildings and features relies on 

local craftsmen rather than replacement 

parts, and these structures generally 

make up the heart of our towns and 

cities. Many organizations are providing 

helpful guidance on sustainable practices 

in historic preservation. These resources 

include how-to video clips, checklists, 

and programming to support historic 

properties.

The National Park Service finds that 

sustainability is the nexus of society, 

the environment, and the economy. 

In recognition of the role the built 

environment plays in energy use, NPS 

has emerged as a leader among federal 

agencies, developing guidance and 

technical information on incorporating 

sustainable practices to reduce energy 

consumption, while maintaining those 

characteristics that make historic 

properties significant as part of its 

mission. Several NPS initiatives include 

the following:

The Secretary of the Interior’s 

Standards for Rehabilitation 

& Illustrated Guidelines on 

Sustainability for Rehabilitating 

Historic Buildings

The Secretary of the Interior’s Standards 

for Rehabilitation & Illustrated Guidelines 

on Sustainability for Rehabilitating 

Historic Buildings are an important 

addition to current discussions about 

sustainability and achieving greater energy 

efficiency, which have focused primarily on 

new buildings to date. Released in April 

2011, the Guidelines stress the inherent 

sustainability of historic buildings and 

offer specific guidance on “recommended” 

rehabilitation treatments and “not 

recommended” treatments, which could 

negatively impact a building’s historic 

character. Illustrations of both types of 

treatments are included. The guidelines 

are designed to assist building owners in 

planning rehabilitation projects that will 

meet the standards for rehabilitation.

The Guidelines supplement the Secretary of 

the Interior’s Standards for Rehabilitation 

and Guidelines for Rehabilitating Historic 

Buildings, which are one of the four 

Secretary of the Interior’s Standards for the 

Treatment of Historic Properties, (the other 

“Standards” are preservation, restoration, 

and reconstruction). These four sets of 

standards, developed by NPS in the 1980s, 

fulfilled the Secretary of the Interior’s 

responsibility to advise federal agencies on 

the preservation of historic properties listed 

in or eligible for listing in the National 

Register of Historic Places.

The Secretary of the Interior’s Standards for Rehabilitation & Illustrated Guidelines on 

Sustainability for Rehabilitating Historic Buildings are an important addition to current 

discussions about sustainability and energy efficiency.

CASE STUDY

The National 

Park Service and 

Sustainability—At 

the Forefront of 

Assisting Federal 

Agencies

FEDERAL AGENCY 

National Park Service 

LOCATION 

Nationwide

CREDIT: NPS

CHAPTER 1—INTRODUCTION AND BACKGROUND | 19

CONTINUED >>>
Preservation Brief #3: 

Improving Energy Efficiency in 

Historic Buildings

At the end of 2011, the NPS issued an 

updated Preservation Brief #3 on energy 

efficiency in historic buildings. While 

this brief is limited to issues related to 

energy efficiency, and does not address the 

larger topic of sustainability, it updates a 

previous Preservation Brief #3 on energy 

conservation and includes information 

on actions to improve energy efficiency, 

inherent energy efficient features of historic 

buildings, energy audits, and alternative 

energy sources.

Updated NPS Webpage on 

Sustainability and Energy 

Efficiency

NPS, Technical Preservation Services has 

developed a new Webpage highlighting 

preservation of historic buildings and issues 

of sustainability, energy efficiency, and new 

technologies and research. This resource 

for federal agencies and the public includes 

information on such new technologies 

as green roofs, solar panels, and wind 

turbines. It also provides information on 

weatherization and energy conservation 

and features case studies highlighting 

projects across the country that successfully 

combine historic rehabilitation with green 

building practices.

CASE STUDY | The National Park Service and Sustainability—At the 

Forefront of Assisting Federal Agencies (continued)

20 | CHAPTER 1—INTRODUCTION AND BACKGROUND
FRAMEWORK FOR 2012 REPORT TO THE PRESIDENT

The ACHP is using five thematic areas, including four established in the 2009 

Report to the President, to group findings and recommendations consistent with 

the goals of the EO and current Administration initiatives. They are the following:

» Contributing to the Economy. Through a variety of agency activities and 

collaborative ventures, federally owned historic properties and preservation 

programs can be an excellent means for promoting economic development 

and heritage tourism locally and regionally.

» Building Partnerships. Public-private partnerships for the identification, 

protection, and use of federally owned historic properties when consistent 

with agency missions can be effective in caring for resources, engaging 

volunteers, educating the public, promoting local economic development and 

heritage tourism, and help lessen the financial burden of federal agencies to 

accomplish the tenets of this EO.

» Managing Assets. The establishment of procedures to ensure the 

protection and use of historic properties within an agency’s mission will allow 

that agency to fully comply with NHPA and EO 13514.

» Integrating Stewardship into Agency Planning. The inclusion of 

historic property management needs within an agency’s strategic plans can 

significantly support the stewardship goals outlined in NHPA, EO 13287, and 

EO 13514.

» Enhancing and Improving Inventories of Historic Properties. An 

accurate, comprehensive inventory and evaluation of an agency’s historic 

properties allows a greater understanding of the value and management 

requirements of these historic properties. In turn, this inventory provides the 

necessary foundation for meeting further management goals such as disposal 

of unneeded federal real estate.

While the ACHP anticipated adapting these thematic categories to address future 

requirements, policies, and challenges in the management of federal real property, 

these categories continue to effectively frame a discussion on current real 

property management issues in the stewardship of federal historic properties.

CHAPTER 1—INTRODUCTION AND BACKGROUND | 21
Solar panels provide 

alternate energy 

on Bureau of Land 

Management land, 

California

CHAPTER 2: CURRENT STATE 

OF FEDERAL REAL PROPERTY 

MANAGEMENT

THE CURRENT STATE of federal real property management is transforming. 

According to the Fiscal Year 2009 Federal Real Property Statistics, prepared 

by GSA from the Federal Real Property Profile, the federal government owns, 

manages, and administers in excess of 39 million acres of land (which does not 

include mineral rights) and 429,000 building assets (many of which are historic), 

comprising approximately 3.34 billion square feet. Agencies continue efforts to 

ensure that the federal government’s assets are mission critical, sustainable, and 

energy efficient. As reported in the 2009 Report to the President, the Statement 

of Federal Financial Accounting Standards 29 and EO 13327, “Federal Real 

Property Management,” still have commanding influence over the inventory of a 

federal agency’s real property and integration of a preservation ethic in overall 

agency strategic planning. The Obama Administration took a number of actions in 

the past three years that have had an effect on federal real property management 

and the federal stewardship of historic properties. A summary of several of these 

actions and their relationship to the stewardship of historic properties follows.

CREDIT: BLM
AMERICAN RECOVERY AND REINVESTMENT ACT (2009)

The Recovery Act was an unprecedented effort to jumpstart the economy 

and create or save millions of jobs. OMB issued guidance in March 2009, that 

recognized compliance with the National Environmental Policy Act and NHPA 

was required for Recovery Act projects. Many of the projects funded through the 

Recovery Act supported the preservation and productive use of federal historic 

properties and directly benefited local economic vitality and infrastructure and 

opportunities to demonstrate the economic value of preservation through job 

creation, community revitalization, and sustainable development.

EXECUTIVE ORDER NO. 13514, “FEDERAL LEADERSHIP 

IN ENVIRONMENTAL, ENERGY, AND ECONOMIC 

PERFORMANCE” (2009)

EO 13514 states that

the policy of the United States that Federal agencies shall increase energy 

efficiency; measure, report, and reduce their greenhouse gas emissions from direct 

and indirect activities; conserve and protect water resources through efficiency, 

reuse, and stormwater management; eliminate waste, recycle, and prevent pollution 

leverage agency acquisitions to foster markets for sustainable technologies and 

environmentally preferable materials, products, and services; design, construct, 

maintain, and operate high performance sustainable buildings in sustainable 

locations; strengthen the vitality and livability of the communities in which Federal 

facilities are located; and inform Federal employees about and involve them in the 

achievement of these goals.

Major provisions of this EO include the reduction of federal greenhouse gas 

emissions by FY 2020; the development of Strategic Sustainability Performance 

Plans; advancement of regional and local integrated planning; implementation of 

high performance sustainable federal building design, construction, operation and 

management, maintenance, and deconstruction; and the establishment of the Steering 

Committee on Federal Sustainability and Agency Senior Sustainability Officers.

ISSUANCE OF PRESIDENTIAL MEMORANDUM—

AMERICA’S GREAT OUTDOORS (2010)

President Obama issued this Presidential Memorandum directly to the 

Secretaries of the Interior and Agriculture, the Administrator of the 

Environmental Protection Agency, and the Chair of the CEQ. Through outreach, 

interdepartmental coordination, interagency collaboration, and reporting, 

President Obama challenged the federal government, the nation’s largest land 

manager, to support community-driven efforts to identify the places that mean 

the most to Americans. This includes historic and cultural resources, leveraging 

the support of the private sector and nonprofit organizations, and establishing 

partnerships to reconnect these spaces to Americans and each other with a 

CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT | 23
Rehabilitation of historic properties can 

play a critical role of the sustainability 

strategy set forth in Executive Order 13514, 

“Federal Leadership in Environmental, 

Energy, and Economic Performance,” 

and the Advisory Council on Historic 

Preservation (ACHP) is encouraging the 

full integration of preservation into the 

federal government’s policies and programs 

addressing energy efficiency and community 

livability. Since almost half of the country’s 

greenhouse gas emissions come from the 

construction, operation, and demolition of 

buildings, the reuse and retrofit of historic 

buildings can lead to significant reductions 

in these emissions, a principal goal of EO 

13514. In addition, preservation of historic 

properties directly supports the EO’s 

emphasis on strengthening the vitality and 

livability of communities in which federal 

facilities are located.

The ACHP established a Task Force on 

Sustainability and Historic Preservation 

in 2010. The Task Force members include 

representatives of the Departments of 

Energy, Housing and Urban Development, 

Interior, and Transportation; the 

Environmental Protection Agency; the 

Architect of the Capitol; the National Trust 

for Historic Preservation; the National 

Conference of State Historic Preservation 

Officers; and it is chaired by an ACHP 

expert member, who is an architect. Other 

ACHP members participating in the 

Task Force include representatives of the 

General Services Administration and the 

Departments of Defense and Veterans 

Affairs. With the assistance of the Task 

Force, the ACHP has completed or initiated 

a number of activities related to energy 

efficiency and community livability.

Notable among the initiatives addressing 

energy efficiency was the development 

of guidance, Sustainability and Historic 

Federal Buildings, released in May 2011 

and available on the ACHP Web site. The 

ACHP developed the guidance to assist 

federal agencies in their efforts to meet 

the expectations of EO 13514 regarding 

retrofitting of federally owned buildings 

while also meeting the requirements 

of the National Historic Preservation 

Act. In addition, this guidance addresses 

the intersection of historic preservation 

policy with the recommendations of the 

Department of Transportation and other 

federal agencies for selecting sustainable 

locations for federal facilities, prepared 

pursuant to Section 10 of EO 13514. The 

goal of this guidance is to assist federal 

decision makers, usually capital asset 

managers, facility managers, and other 

program and project managers, in their 

considerations regarding sustainability and 

historic federal buildings.

The ACHP also has contributed to the 

national dialogue on energy efficiency 

by commenting on a variety of relevant 

standards and guidelines that are under 

The Department of Treasury’s Washington, D.C. headquarters was awarded Leadership in 

Energy and Environmental Design Gold certification from the U.S. Green Building Council in 

December 2011. It is believed to be the oldest building to achieve Gold status in the world. 

The rehabilitation of this National Historic Landmark is believed to produce an estimated $3.5 

million in energy and lease cost savings annually to the Treasury. It is an example for other 

federal agencies in meeting the goals of EO 13514 and protection and use of historic assets. 

CASE STUDY

Advisory Council 

on Historic 

Preservation’s 

Contributions to 

Implementation of 

EO 13514

FEDERAL AGENCY 

Advisory Council on Historic 

Preservation 

LOCATION 

Nationwide

CREDIT: ACHP

24 | CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT
development or recently issued, including 

the following: the Secretary of the 

Interior’s Standards for Rehabilitation & 

Illustrated Guidelines on Sustainability for 

Rehabilitating Historic Buildings and the 

National Park Service’s revised Preservation 

Brief #3: Conserving Energy in Historic 

Buildings; the U.S. Green Building 

Council’s revised Leadership in Energy 

and Environmental Design Green Building 

Rating Systems; the federal Interagency 

Sustainability Working Group’s revised 

“Guiding Principles for Federal Leadership 

in High Performance and Sustainable 

Buildings;” and the revised International 

Green Construction Code. The ACHP also 

commented to the Department of Energy 

on ways to ensure that historic properties 

are adequately addressed in its proposed 

Commercial Building Asset Rating Program, 

its commercial building workforce guidance, 

and its proposed rule on energy efficiency 

and sustainable design standards for new 

federal buildings.

Regarding preservation and sustainable 

community development, the ACHP 

provided comments to EPA on its new 

“School Siting Guidelines” and advised 

it on the selection of a preservation 

demonstration project for funding through 

its Smart Growth Implementation 

Assistance Program. The ACHP also served 

on the working group which developed the 

recommendations central to the Council 

on Environmental Quality’s “Guidance for 

Federal Agencies on Sustainable Practices 

for Designed Landscapes.”

During 2012, the ACHP Sustainability 

Task Force will continue to promote 

consideration of historic properties 

as federal agencies comply with the 

requirements of EO 13514 regarding the 

energy performance of existing buildings 

and sustainable community development. 

The Task Force also will work to identify 

opportunities for federal agencies to address 

sustainability through the review process 

established by Section 106 of NHPA.

CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT | 25
21st century conservation and recreation agenda. Specifically the memorandum 

required a report on America’s great outdoors that provided the following:

» a review of successful and promising nonfederal conservation approaches;

» an analysis of existing federal resources and programs that could be used to 

complement those approaches;

» proposed strategies and activities to achieve the goals of the initiative; and

» an action plan to meet the goals of the initiative.

A report was issued in February 2011 which included a specific goal to protect 

America’s historic and cultural resources, recognizing that historic preservation 

can revitalize communities, serve as a catalyst to bolster local economies, 

support local businesses, and increase job opportunities. The report put forth 

two recommendations related to cultural resource management: the federal 

government should (1) elevate the importance of cultural resources planning, 

protection, and interpretation in the federal land management agencies and, (2) 

expand support for state, tribal, and community historic preservation efforts for 

capital projects, planning, interpretation, community-based surveying, and technical 

assistance that support partnerships and community-based preservation activities.

ISSUANCE OF PRESIDENTIAL MEMORANDUM—

DISPOSING OF UNNEEDED FEDERAL REAL ESTATE (2010)

President Obama has directed the executive branch to eliminate wasteful spending 

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

pollution, pursuant to EO 13514, and the Federal Data Center Consolidation 

Initiative by:

» accelerating efforts to identify and eliminate excess real property;

» taking immediate steps to make better use of remaining real property as 

measured by utilization and occupancy rates, annual operating cost, energy 

efficiency, and sustainability;

» to the extent permitted by law, include accelerating cycle times for

» identifying excess assets and disposing of surplus real property;

» eliminating lease arrangements that are not cost effective;

» pursuing consolidation opportunities within and across agencies in 

common asset types (such as data centers, office space, warehouses, and 

laboratories);

» increasing occupancy rates in current facilities through innovative 

approaches to space management and alternative workplace 

arrangements, such as telework; and

» identifying offsetting reductions in inventory when new space is acquired.

OMB was directed to work with GSA and the Federal Real Property Council to 

issue guidance for actions agencies should take to carry out the requirements 

26 | CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT
The United States Army Corps of Engineers 

administers one of the largest federal 

collections of archaeological artifacts and 

associated records. Most of these collections 

were excavated during construction of 

reservoirs and associated water control 

programs from 1947 to 1985. Federal law 

requires that these archaeological collections 

be stored in a manner to ensure their longterm preservation and to facilitate access 

for scientific research and public education. 

Using American Recovery and Reinvestment 

Act funding, the USACE established a 

unique and beneficial program to manage 

these collections and provide temporary 

employment and training to wounded 

veterans. Project participants are employed 

in a structured and supportive environment, 

earning full- or part-time salaries as they 

acquire skills to help them reintegrate into 

the civilian workforce.

USACE St. Louis District’s Mandatory 

Center of Expertise for the Curation 

and Management of Archaeological 

Collections developed the Veterans 

Curation Project with $3.5 million 

in Recovery Act funding to provide 

training with professional archaeological 

laboratory management specialists to 

wounded veterans, teaching them to 

describe, process, and curate USACE 

archaeological collections using a variety 

of standard and specialized processes 

and equipment found in a professional 

archaeological and archival processing 

laboratory.

The VCP has two goals:

» Train veterans in technical skills 

including cataloging, database and 

records management, preserving 

historical documents, digital 

photography, scanning, and making 

information available online.

» Curate and reduce the backlog 

inventory of artifacts, images, and 

records from collections owned and/or 

managed by USACE.

Three VCP laboratories have been opened 

in the past two years: Augusta, Georgia; St. 

Louis, Missouri; and Washington, D.C./

Alexandria, Virginia. Assistant Secretary 

of the Army (Civil Works) Jo-Ellen Darcy, 

speaking at the Augusta VCP laboratory 

public opening said, “No group of people 

has done more to forge our national identity 

throughout history than the veterans who 

have served and sacrificed for the nation. It is 

our privilege to now be able to give disabled 

veterans an opportunity to continue shaping 

the nation through the work and training 

they will do at this important new facility.”

To date, 77 veterans have been trained by 

the VCP, and nine veterans are currently 

being trained in the St. Louis laboratory. 

Training resumed in the Augusta and 

Alexandria laboratories in January 2012. 

Forty-one veterans who participated in the 

VCP have obtained long-term employment 

using the skills gained in the VCP program 

in combination with their previous 

military experience, and 16 veterans have 

continued their education at colleges, 

universities, and certificate programs.

The USACE, and its St. Louis District, 

received the Advisory Council on Historic 

A participant in the Veterans Curation Project is working with records associated with an 

archaeological investigation. 

CASE STUDY

Job Creation 

Through Recovery 

Act Funding

FEDERAL AGENCY 

U.S. Army Corps of Engineers 

LOCATION 

Nationwide

CREDIT: USACE

CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT | 27

CONTINUED >>>
CASE STUDY | Job Creation Through Recovery Act Funding (continued)

United States Army Corps of Engineers Mississippi Valley Division Commander Major General 

John W. Peabody reviews data entry for archaeological investigations with a participant in the 

Veterans Curation Program. 

Preservation Chairman’s Award for Federal 

Achievement in Historic Preservation for 

the VCP in December 2009. The VCP is 

facing an uncertain future due to federal 

budget constraints and is looking for an 

infusion of funding to continue its valuable 

program for veterans.

An initiative to support USACE districts 

in compliance with Section 110 of the 

National Historic Preservation Act 

was undertaken using $25 million in 

Recovery Act funding. Work proceeded 

in 36 USACE districts to survey and 

identify archaeological and historic 

cultural resources on USACE fee-title 

lands. A readily accessible map of cultural 

resources using Geographic Information 

Systems software is being created for use 

with CorpsMap. This funding promoted 

efforts which were at first believed to 

be accomplished in a decade yet were 

completed in less than two years with a 

substantial gain to the cultural resources 

management industry. Nineteen individual 

private sector firms were sustained by 

these efforts. Lastly, USACE used $1.2 

million in Recovery Act funding to 

improve USACE compliance with the 

Native American Graves Protection 

and Repatriation Act. It is anticipated 

this will streamline the cataloguing of 

artifacts held by the USACE and lead 

to the appropriate disposition of human 

remains to appropriate tribal entities in an 

expedited manner.

Through these innovative projects 

funded through the Recovery Act, the 

USACE has shown leadership in creating 

partnerships to manage cultural resources 

while assisting wounded veterans through 

productive work opportunities, as well as 

in fulfilling various federal responsibilities 

in an expedited manner.

CREDIT: USACE

28 | CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT
of the memorandum. A legislative proposal (known as the Civilian Property 

Realignment Act) was introduced in Congress under H.R. 1734 and S. 1503 

in 2011. OMB established a Real Property Advisory Committee in May 2011 

to continue making progress on minimizing waste and the efficient disposal 

of federal real property. The RPAC will consist of three Senior Real Property 

Officers and four Chief Financial Officers selected by the OMB Controller. The 

RPAC will operate under three basic principles: (1) spending on inefficient real 

property is no longer an option; (2) new technologies have changed how the 

government does its work; and (3) better management of real property helps 

achieve sustainability goals.

ISSUANCE OF PRESIDENTIAL MEMORANDUM—

SPEEDING INFRASTRUCTURE DEVELOPMENT 

THROUGH MORE EFFICIENT AND EFFECTIVE 

PERMITTING AND ENVIRONMENTAL REVIEW (2011)

This Presidential Memorandum states that

to maintain our Nation’s competitive edge, we must ensure that the United 

States has fast, reliable ways to move people, goods, energy, and information. In 

a global economy, where businesses are making investment choices between 

countries, we will compete for the world’s investments based in part on the 

quality of our infrastructure.

Recognizing that the federal government has a central role in ensuring that 

infrastructure projects move as efficiently as possible, President Obama has 

instructed federal agencies to “(1) identify and work to expedite permitting and 

environmental reviews for high-priority infrastructure projects with significant 

potential for job creation; and (2) implement new measures designed to improve 

accountability, transparency, and efficiency through the use of modern information 

technology” in partnership with state, local, and tribal agencies. Secretaries of 

Agriculture, Commerce, Housing and Urban Development, the Interior, and 

Transportation have each identified high-priority projects effecting infrastructure 

projects on and off federally controlled land.

CORRELATION TO AGENCIES’ SECTION 3 

PROGRESS REPORTS

Collectively, these federal initiatives aim to produce better organization and 

efficiency for federal agencies managing property inventories. Agencies are 

collecting and reporting real-time property data that can be used to determine 

which properties should be maintained, require cost-effective repairs, or qualify 

for disposal. However, despite the general trend toward improvement, agencies 

continue to face many of the same challenges in the management of historic 

properties in 2012 that were initially reported by the ACHP in 2009. These include 

the following:

CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT | 29
President Barack Obama issued the 

America’s Great Outdoors Presidential 

Memorandum directly to the Secretaries 

of the Interior and Agriculture, the 

Administrator of the Environmental 

Protection Agency, and the Chair of the 

Council on Environmental Quality in 

2010. Through outreach, interdepartmental 

coordination, and reporting, President 

Obama challenged the federal government, 

the nation’s largest land manager, to support 

community-driven efforts to identify the 

places that mean the most to Americans, 

to include historic and cultural resources, 

leverage the support of the private sector 

and nonprofit organizations, and establish 

partnerships to reconnect these spaces 

to Americans and each other with a 21st 

century conservation and recreation agenda.

After extensive study and outreach, a report 

issued in February 2011, included eight 

sets of findings and recommendations 

to implement AGO goals. In addition to 

recommendations related to land and water 

conservation, outdoor recreation, natural 

resource management, and community and 

youth education and outreach, the report 

recommended improvements to cultural 

resource management planning as well as 

support for relevant historic preservation 

partnerships. Other programmatic 

recommendations, for example on public 

outreach, explicitly include fostering 

appreciation for cultural heritage values 

as part of AGO.

Since its inception and the report to the 

President, agencies have been pursuing AGO 

goals through interagency work as well as 

careful examination of individual agency 

program priorities for Fiscal Year 2012 and 

beyond. While not specifically identified as 

supporting the AGO initiative, several of the 

2011 Section 3 progress reports described 

public-private partnership projects and 

programs that support AGO goals.

On February 25, 2009, about 100 refuge 

visitors, neighbors, and partners joined 

U.S. Fish and Wildlife Service Deer Flat 

National Wildlife Refuge staff to celebrate 

100 years of working together for wildlife. 

Centennial preparations began when the 

Friends of Deer Flat Wildlife Refuge 

applied for a Preserve America Grant 

to conduct historical research about the 

refuge and reservoir. With grant funds, 

matching and in-kind contributions from 

11 partners, and assistance from a variety 

of Friends members and refuge volunteers, 

the project is nearing completion. Project 

partners and volunteers have made 

a variety of contributions, including 

donations of cash, assistance with 

historical research, laying out and 

designing interpretive signs, a pamphlet, 

and much more.

The U.S. Army Corps of Engineers, 

Albuquerque District, Cochiti Lake, 

and the Jemez Canyon Dam Projects 

are located on the reservations of the 

Pueblo de Cochiti and the Pueblo of 

Santa Ana. The Albuquerque District has 

been working closely with the Pueblo de 

Cochiti to compile a baseline data set of 

tribal assets and historic documentation 

regarding USACE interaction with the 

federally recognized Indian tribe. This 

includes data such as natural, water, and 

Members of the Licking County Bicycle Club cross the historic Squire Whipple Bow String Truss 

Bridge along a public recreation trail in Newark, Ohio. 

CASE STUDY

America’s Great 

Outdoors and 

Historic Resource 

Stewardship

FEDERAL AGENCY 

Various Federal Agencies 

LOCATION 

Nationwide

CREDIT: TIMOTHY E. BLACK / GREATER LICKING COUNTY CONVENTION AND VISITORS BUREAU

30 | CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT
archaeological resources as well as historic 

photography and Geographic Information 

System data. For the past two years the 

Pueblo de Cochiti has sponsored the 

USACE Native American Environmental 

and Cultural Resources Training at the 

Pueblo. In 2007 and 2009 Cochiti Pueblo 

middle school students attended day trips 

to two archaeological sites in the Cochiti 

Lake Campground where Albuquerque 

District archaeologists and biologists 

explained how the USACE and the 

Pueblo are working together to identify 

and document natural, biological, and 

archaeological resources. This helps the 

students learn about the local landscape 

and how USACE projects relate to the 

modern Pueblo.

In October 2011, a progress report and 

action plan took these recommendations 

a step further, outlining combined 

conservation and recreation successes, 

including gains in youth employment, 

new trail designations, the creation of 

urban campgrounds, and investments in 

large landscape conservation. In addition 

to natural and cultural resource values, 

the progress report detailed how 

America’s public lands and private farms, 

ranches, and forests provide vital jobs 

and economic, educational, and social 

benefits to citizens and communities 

across the country.

CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT | 31
» lack of accurate and available information regarding the presence and value of 

historic assets in the agency’s real property portfolio;

» limited resources to support historic property identification, condition 

assessments, maintenance, and capital improvement projects;

» existence of conflicting regulations and directives regarding the management 

and disposal of real property assets; and

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

properties to support agency missions.

Recognition of these new challenges resulted in the ACHP revising its Section 3 

Advisory Guidelines in 2011 to address the current Administration’s policies and 

directives. Through an agency’s submission of its progress reports, federal agencies 

play a key role in assisting the ACHP in fulfilling these goals:

» Federal agencies can use Section 3 progress reports to assess the 

effectiveness of and improve their preservation programs in conjunction with 

existing reporting requirements, both internally and externally.

» The process of gathering information, analyzing data, and developing the 

Section 3 progress reports can assist the ACHP and federal agencies in 

evaluating agency efforts to incorporate the identification, protection, and 

use of historic properties into overall agency strategic planning and asset 

management.

» Consistent Section 3 progress reporting by federal agencies enhances the 

quality and utility of the ACHP’s Report to the President on the status of 

federal preservation programs.

Agencies were further encouraged to report on their progress in resolving the 

issues identified in the ACHP’s 2009 Report to the President.

Recognition of 

these new challenges 

resulted in the 

ACHP revising its 

Section 3 Advisory 

Guidelines in 2011 

to address the current 

Administration’s 

policies and directives.

32 | CHAPTER 2—CURRENT STATE OF REAL PROPERTY MANAGEMENT
The renovation of the Koen 

Building at the Ozark-St. 

Francis National Forest, 

Arkansas, has kept the 

historic fabric intact and 

brought the building up 

to current accessibility 

standards and building codes. 

An addition designed to 

resemble the original building 

was certified Leadership in 

Energy and Environmental 

Design Gold in July 2010. 

CHAPTER 3: CURRENT STATE OF 

FEDERAL STEWARDSHIP

AS AGENCIES MEET THE GOALS of inventory reduction, sustainable 

infrastructure, and fiscal responsibility, the requirements of identification, protection, 

and use of historic properties informs federal agencies in meeting these 

Administration initiatives. The progress reports submitted in 2011 demonstrate 

federal agencies are utilizing a broad range of tools, approaches, and partnerships 

to achieve the objectives of EO 13287.

Using the five established thematic areas under the framework described in 

Chapter 1, the ACHP reviewed all the 2011 Section 3 progress reports submitted. 

The ACHP developed the 2011 advisory guidelines to assist agencies by providing 

a reporting framework that could be used to integrate information from multiple 

reporting requirements. A review of these progress reports demonstrated that 

agencies continue to make progress in the identification, protection, and use 

of historic properties in their ownership, yet they confront many challenges in 

doing so, some different than previously identified. The following summarizes 

this progress in the five thematic areas identified by the ACHP. Because not all 

agencies used the advisory reporting guidelines, and they are not mandatory, the 

information provided was not universally comparable.

CREDIT: FS
Agencies’ 2011 Section 3 Progress Reports are available on the ACHP Web site. 

Appendix D provides a full accounting of agency reporting.

CONTRIBUTING TO THE ECONOMY

Through a variety of agency activities and collaborative ventures, federally owned 

historic properties and preservation programs can be an excellent means for 

promoting economic development and heritage tourism locally and regionally. 

Public-private partnerships provide opportunities for states, tribes, and localities to 

generate tax revenues, tourism dollars, jobs, and other tangible economic benefits.

The 2009 Report to the President found:

While federal agencies and the historic properties under their ownership or 

control have tremendous potential to contribute to local economic development 

through job creation, public-private partnerships, property management practices, 

and participation in local and regional heritage tourism initiatives, they have not 

systematically done so.

With some notable exceptions, this does not appear to have changed significantly 

since the 2008 reporting cycle. The National Park Service progress report 

indicates that visitors to its national parks, many of which center on the protection 

and interpretation of nationally significant historic properties, contributed more 

than $14.2 billion to nearby communities in 2009. This striking statistic conveys 

the enormous impact that heritage tourism alone can have on local economies 

and the clear value for the investment of federal dollars in this endeavor. By their 

own admission, agencies struggle to develop accurate and meaningful methods 

to measure and report these impacts, a fact that remains evident in the 2011 

progress reports. Very few summary statistics were reported for these impacts 

other than by NPS. Many communities, whether or not they technically serve 

as “gateways” to these lands, continue to rely heavily on the presence of national 

parks, national forests, public lands, or other federal assets for local and regional 

economic benefits, including heritage tourism. Therefore, issues related to the 

condition of such assets and the agency’s commitment to maintaining them 

remain fundamentally important to these communities. When included early on 

in the development of heritage tourism and economic redevelopment initiatives 

relating to historic properties, it is these stakeholders who can bring to an agency’s 

attention the community’s long-term vision and goals for using and benefitting 

from such properties.

A major federal presence, including the existence of significant federally owned 

or managed lands and assets, can have a tremendous impact on local economies. 

However, it is not a simple matter to identify those instances where historic 

properties under federal ownership or control are specifically contributing to local 

economic opportunity, job creation, or increased investment. Occasionally a direct 

link can be demonstrated through the presence of a significant federally owned 

historic property that is a local or regional tourism attraction (e.g., the Statue 

of Liberty), a federal historic property that is managed or operated by a private 

AGENCY PROGRESS REPORTING 

BETWEEN 2005, 2008, AND 2011

Please note that the number of agencies 

reporting continues to fluctuate as agencies self 

select out of future progress reporting, individual 

bureaus and agencies submit progress reports 

separately from parent agencies or will no longer 

submit from the parent agency, or the agency 

does not submit a progress report.

2005 2008 2011

23 21

24

34 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
enterprise for profit (e.g., a historic lodge), or a federal property that is in active 

use in a community for its original, or a modified purpose, and is helping to anchor 

other area economic development (e.g., a federal courthouse).

Several federal agencies reported on projects and programs they have carried out 

over the last several years that have helped support local economic development 

either directly or indirectly. Examples of agency programs and partnerships are 

given below in three general categories: recreation and tourism, cooperative 

management and use, and community revitalization. Each of these sectors has the 

potential to create jobs and support economic vitality.

RECREATION AND TOURISM

On many public lands, historic properties may become attractions whose 

economic worth is included in more general measurements of outdoor 

recreation use. According to the 2011 Department of the Interior report on the 

Department’s contributions to the U.S. economy,

“Americans and foreign visitors made some 439 million recreation-related visits 

to Interior-managed lands in 2010. These visits supported over 388,000 jobs 

and contributed over $47 billion in economic activity. This economic output 

represents about 8% of the direct output of tourism-related personal consumption 

expenditures for the United States for 2009 and about 1.3% of the direct tourism 

related employment.”

Of this total, approximately $30.39 billion and 246,956 jobs are attributable to 

NPS, $3.98 billion and 32,564 jobs to the U.S. Fish and Wildlife Service, $7.43 

billion and 58,947 jobs to the Bureau of Land Management, and $6.07 billion and 

49,660 jobs to the Bureau of Reclamation. A similar 2011 report from the Forest 

Service found that “recreation activities on National Forests and Grasslands sustain 

223,000 jobs in the rural communities within 50 miles of the national forests and 

grasslands, where visitors purchase goods and services for their recreational activity. 

Visitors spend $13 billion directly in those communities within 50 miles of the 

national forests and grasslands.”

The nation’s public lands constitute important national economic assets. National 

Parks, National Wildlife Refuges, and large portions of the public lands contribute 

to employment through a wide range of uses, visitor services and concessions, 

outfitters and suppliers, and other sectors. These are largely private-sector jobs. 

Concessionaires or outfitters may run businesses that focus on day tours or backcountry trips to important sites on public lands, such as remote archaeological sites, 

rock art sites, or similar destinations.

Tourism in general is big business. In 2010, travel and tourism directly contributed 

$759 billion to the U.S. economy. Travel and tourism is one of America’s largest 

employers, directly employing more than 7.4 million people and creating a payroll 

income of $188 billion, and $118 billion in tax revenues for federal, state, and local 

governments. In addition to creating new jobs, new business, and higher property 

values, well-managed tourism improves the quality of life and builds community 

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 35
and regional pride. According to a 2009 national research study on U.S. Cultural 

and Heritage Travel by Mandela Research, 78 percent of all U.S. leisure travelers 

participate in cultural and/or heritage activities while traveling translating to 118.3 

million adults each year. Cultural and heritage visitors spend, on average, $994 per 

trip compared to $611 for all U.S. leisure travelers.

Heritage tourism is the business or 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, and culture. It can also be an important agent in 

promoting community pride, enhancing quality of life, and educating present and 

future generations. As communities try to understand and appreciate their own 

heritage, and focus on presenting their heritage to tourists and other visitors, 

they gain increased appreciation for what they themselves have. Communities 

must make decisions about local priorities in preservation, in public interpretation, 

in visitor services, and in other investment. Reuse and revitalization of historic 

properties for visitors, if carefully managed, can help protect important resources 

and assist the community in retaining its unique identity and sense of place. 

Heritage tourism can also bring attention to the stories and traditions of the past 

that are most important to the community’s foundations and to its continued 

development and vitality.

Several federal agencies reported on creative tourism strategies given security 

constraints. BOR’s primary mission to deliver water and power defines the use of its 

facilities, historic or otherwise. Historic dams, power plants, irrigation structures, and 

buildings that continue to support that mission are in active use. Security concerns 

and dangerous conditions severely restrict public visitation opportunities at BOR’s 

historic properties. Although security and safety concerns limit opportunities to 

utilize active historic properties to promote local economic development and 

heritage tourism, BOR continues to seek “offsite” opportunities to inform the 

public of its historic properties and foster heritage tourism. BOR maintains a 

cultural resources Web site with a page called “Promoting Our Past” that provides 

information on viewing BOR historic properties and visitor centers. Hoover Dam 

NHL continues to be a tourist destination for visitors to the Las Vegas, Nevada, area, 

and behind-the-scenes tours of the dam remain popular. Grand Coulee Dam on 

the Columbia River between Oregon and Washington is regionally known for a laser 

light show projected on the dam’s downstream face. The light show, supported by 

a pre-recorded narrative, presents BOR’s account of events leading to construction 

of the dam. It is a sufficiently significant tourist attraction that local hotels note a 

reduction in business when the light show is not operating.

The National Aeronautics and Space Administration’s stewardship of historic 

properties has consistently featured a visitor component. These public programs 

have had a huge economic impact on the areas surrounding Kennedy Space 

Center in Florida, and have also resulted in significant benefits near other major 

NASA facilities like Johnson Space Center in Houston, Texas. Where practical, 

NASA has provided access to the public to view significant places in the nation’s 

space program history. Kennedy Space Center’s Visitors’ Center continues to draw 

Reuse and revitalization 

of historic properties 

for visitors, if carefully 

managed, can help 

protect important 

resources and assist the 

community in retaining 

its unique identity and 

sense of place.

36 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
CASE STUDY

Sesquicentennial of 

the American Civil 

War (2009-2015)

FEDERAL AGENCY 

Various Federal Agencies 

LOCATION 

Nationwide

The 150th anniversary of the American 

Civil War is taking place from 2009-2015. 

Unlike some past commemorations, such 

as the U.S. Bicentennial in 1976 or the 

Lewis and Clark Bicentennial in 2003-2006, 

there is no national commission leading the 

planning. Various states have formed state 

commissions, some of them well-funded. 

Even where official commissions are not 

established, most activity is being conducted 

on the state and local level, but the federal 

government can and will play a huge role in 

advancing and supporting this effort.

More than 70 units of the National Park 

System have resources related to the history 

of the Civil War, from its beginnings to 

the Confederate surrender at Appomattox 

Courthouse, Virginia. The National Park 

Service has established a special Web site 

dedicated to the Civil War Sesquicentennial. 

In addition, federal agencies are also 

featuring selected historic properties that 

played a role in the war years. For example, 

the U.S. Fish and Wildlife Service manages 

the Grove Plantation House on the Ernest 

F. Hollings Ashepoo, Combahee, and Edisto 

Basin National Wildlife Refuge, South 

Carolina, one of only three antebellum 

mansions in that area to survive the Civil 

War. While used for USFWS office space, 

it is now open for visitor tours during the 

sesquicentennial. Within the Department of 

Defense, in addition to obvious associated 

holdings like West Point, New York, and 

the U.S. Naval Academy, Annapolis, 

Maryland, some installations manage 

related sites. Civil War sites at Aquia Creek, 

Virginia, connected with Civil War naval 

action along the Potomac, on Marine Corps 

Base Quantico, have had award-winning 

research work and interpretation. 

Events leading up to the Civil War began at 

least 18 months before Fort Sumter, South 

Carolina, was fired upon. In 2009, John 

Brown’s 1859 raid on the federal arsenal 

at Harpers Ferry, West Virginia, and 

subsequent trial and hanging, became the 

focal point of dozens of commemorative 

activities in West Virginia, Maryland, 

Pennsylvania, and Virginia. Visitation at 

this pivotal NPS site at Harpers Ferry 

National Historical Park, West Virginia, 

increased by nearly 8 percent from 2008 

to 2009. NPS also partnered with the 

ACHP, Harpers Ferry Middle School, and 

the Journey Through Hallowed Ground 

Partnership to create a service learning 

project to engage young people in this 

history. The project featured a series of 

podcasts which the students produced 

about stories of John Brown’s raid that they 

found fascinating. These podcasts are now 

officially a part of the park’s interpretive 

material for the public. At Fort Sumter, 

reenactment programs and other events 

recognize the April 1861 Confederate 

bombardment and occupation of the 

fort, while visitor center and educational 

programs focus on the home front and the 

war’s origins.

The Civil War Sesquicentennial promises 

to have a positive economic impact on 

many communities, while building an 

important educational and tourism base for 

the future. Manassas National Battlefield 

Park in Prince William County, Virginia, 

(a Preserve America Community) was 

the site of two major battles in 1861 and 

Reenactment of the First Battle of Bull Run, Prince William County, Virginia (July 2011) 

CREDIT: © JEFF MAURITZEN AND DISCOVER PRINCE WILLIAM & MANASSAS, VA

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 37

CONTINUED >>>
CASE STUDY | Sesquicentennial of the American Civil 

War (2009-2015) (continued)

1862. A local analysis of economic impacts 

from a series of public events and activities 

held over a three-day weekend in July 

2011 found that the City of Manassas 

increased its restaurant revenue by more 

than $800,000 compared to the previous 

July. This resulted in a 14 percent increase 

in the collected meals tax. About 55 percent 

more sales tax revenue for the month was 

generated in the city’s Old Town historic 

area, as well as nearly 11percent more 

lodging tax receipts. This was in spite of 

a heat wave forcing curtailment of some 

events and reduced overall visitor numbers.

The 13 most-visited National Park units 

associated with the Civil War, including 

Gettysburg National Military Park, 

Pennsylvania; Vicksburg National Military 

Park, Mississippi; Lincoln Home National 

Historic Site, Illinois; Ford’s Theatre 

National Historic Site, Washington, D.C.; 

and Arlington House, The Robert E. Lee 

Memorial, Virginia, had an average 700,000 

visitors in 2010, part of the combined nine 

million visitors the entire National Park 

System saw that year. NPS anticipates 

that these sites will mostly have additional 

increases between now and the end of the 

anniversary period in 2015, in spite of the 

overall economy.

In addition to its economic value, the Civil 

War Sesquicentennial is generally raising 

the visibility of history and preservation, 

and focusing public attention on family, 

community, and the roots of our modern 

social and political systems while building 

outstanding public-private partnerships.

38 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
more than 1.5 million annual visitors with the majority taking tours that enter the 

Center and drive by many iconic and historic sites.

Highlights of the tour of Johnson Space Center are the historic Mission Control 

Center from the Apollo era and other working historic properties housing 

significant shuttle artifacts and functioning simulators. Visitor centers are maintained 

at several other NASA facilities, and the majority of NASA Centers have displays 

or museums with exhibits depicting the history of each location and the role it has 

played in the nation’s space program. NASA maintains a cooperative agreement 

with the Smithsonian Institution to display its artifacts at the National Air and 

Space Museum, thus providing for the long-term care and protection of many 

items associated with NASA’s unique history.

The Department of Energy is associated with five major museums located at or 

near DOE field sites: the American Museum of Science and Energy, Oak Ridge, 

Tennessee (a Preserve America Community); the National Museum of Nuclear 

Science and History, Albuquerque, New Mexico; the Bradbury Science Museum, 

Los Alamos, New Mexico; the Columbia River Exhibition of History, Science, and 

Technology, Richland, Washington; and the Atomic Testing Museum, Las Vegas, 

Nevada. Many DOE field sites maintain visitor centers focusing on presenting the 

science and technology related to that particular DOE national laboratory or 

facility. The Office of Legacy Management’s Weldon Spring, Missouri, and Fernald, 

Ohio, sites document the history of the sites and facilities, remediation efforts, 

and provide trails for hiking, biking, and bird watching. “The Secret City Festival” is 

presented by the City of Oak Ridge, Tennessee, the Arts Council of Oak Ridge, and 

the Oak Ridge Convention & Visitors Bureau each year to celebrate the history 

and heritage of Oak Ridge and to honor those who lived and worked there during 

and after the Manhattan Project. The festival has grown to become one of the 

premiere festivals in the region, drawing more than 25,000 visitors annually.

Periodic historic anniversaries and commemorations can be of great value in 

focusing agency involvement and directing support for heritage tourism. The 

year 2009 also marked the 40th anniversary of the Apollo moon landing, with 

celebrations and events held across the country. Recognition of the War of 1812 

bicentennial starting in 2012 and ending in 2015 is being planned as a major 

activity by the Department of the Navy, the United States Coast Guard, and 

numerous partners.

COOPERATIVE MANAGEMENT AND USE

Cooperative management can be an effective tool to reduce resource burdens 

on federal agencies while improving the stewardship of historic properties. There 

are a variety of approaches that agencies take in cooperatively managing their 

historic properties and making them available for continual use. In some agencies 

concession agreements dictate the management terms of historic lodging or 

other major visitor facilities to concessionaires. The ACHP saw an increase in 

agency reporting uses of alternative management strategies, including the use of 

leases under various federal authorities. As expected, NPS and GSA provided the 

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 39
most information concerning such alternative management strategies. GSA notes 

that it uses Section 111 in order to maintain historic buildings and retain rental 

revenue which is then reinvested in the historic buildings relieving GSA from 

some of the financial liability of maintaining the property with appropriated funds. 

However, GSA also notes in its progress report “declining out leasing revenue as 

GSA relocates tenants from expiring leases or culls the inventory of underutilized 

buildings” as “a healthy reflection of progress toward a sustainable portfolio.”

In 1982, NPS implemented a historic property leasing program authorized under 

Section 111 through publication of regulations, 36 C.F.R. Part 18, Leasing of 

Properties in Park Areas. In 2002, NPS revised these regulations to implement 

not only NHPA authority but also a new leasing authority, Section 802 of the 

National Parks Omnibus Management Act of 1998, which authorizes leasing of 

any real property and allows NPS to retain the income generated. Many of the 

leases authorized by NPS provide for the rehabilitation of the property by the 

lessee in lieu of rent, allowing NPS to reprogram funding to preserve other historic 

properties. NPS, as with FS at historic Timberline Lodge on Mount Hood, Oregon, 

continue to maintain historic and iconic National Park accommodations through 

concession agreements in some of the major western parks. Properties currently 

being leased by NPS include the following:

» The Henry Piper Farmhouse at Antietam National Battlefield, Maryland, which 

remains as part of the 1862 interpreted battlefield landscape and in active use 

as a bed and breakfast business;

» The West House and Christian Smith House at Chesapeake & Ohio Canal 

National Historical Park, Washington, D.C., Maryland, Virginia (a number of 

Lock Keeper’s houses along the C&O are also made available for overnight 

accommodation through the C&O Canal Trust partner organization); and

» Fort Baker at Golden Gate National Recreation Area, California, through a 60-

year lease with a San Francisco developer, who has restored Fort Baker and 

built Cavallo Point, a luxury lodge with a spa, cooking school, and other visitor 

facilities. Cavallo Point also serves as the home of the Institute at the Golden 

Gate, an environmental program of the nonprofit Golden Gate National Parks 

Conservancy in partnership with NPS.

Recognizing the benefits of reuse, FS reported continued use of its 

entrepreneurial activity to explore and develop conversions and adaptive uses 

and reported its continued successes through its Recreation Cabin and Fire 

Lookout Rental Program. Despite the fact that FS has no formal policy to retain 

non-mission-critical properties in its inventory, it has been able to retain some 

excess administrative properties by converting them to recreation rental cabins 

for public use.

NASA has identified Section 111 of NHPA as a useful tool to encourage the 

use of historic buildings that are no longer actively needed and cannot be easily 

disposed or removed from NASA property. GSA successfully used Section 

111 at the John W. McCormack U.S. Post Office and Courthouse in Boston, 

40 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
CASE STUDY

Leasing of Historic 

Properties in 

National Park 

System Units

FEDERAL AGENCY 

National Park Service 

LOCATION 

Valley Forge National Historical 

Park, Pennsylvania

In 1982 the National Park Service 

implemented the leasing of historic 

property authorized by Section 111 

(16 U.S.C. § 470h-3) of the National 

Historic Preservation Act by publication 

of regulation 36 C.F.R. Part 18: Leasing 

of Properties in Park Areas. In 2001, NPS 

adopted a new regulation (by amending 

36 C.F.R. Part 18) that generally governs 

the leasing of park area real property to 

third parties. The new Part 18 combines 

in one regulation the general NPS leasing 

authority provided by Section 802 of the 

National Park Omnibus Management Act 

of 1998 (16 U.S.C. § 1a-2(k)) with the 

NPS leasing authority for historic property 

provided by Section 111 of NHPA, which 

authorizes NPS to lease not only historic 

property, but any real property and to retain 

the income. These authorities are two of five 

general authorities and many park-specific 

authorities available to NPS to manage real 

property in the National Park System.

At Valley Forge National Historical Park, 

Pennsylvania, NPS exercised these leasing 

authorities when it leased the David Walker 

Farmstead to the Montessori Children’s 

House of Valley Forge, an established 

community-based pre-school and not-forprofit 501(c)3 organization. The Farmstead 

is a 3.7-acre site located on the southern 

boundary of the park and includes a 

National Register of Historic Places-eligible 

main house and root cellar, and a noncontributing barn, tenant house, and several 

small outbuildings. None of the buildings 

were present during the Revolutionary 

War encampment of George Washington’s 

Army, and the property does not relate 

to the central theme of the park. In 1978, 

the federal government acquired the farm, 

which remained in a use-and-occupancy 

permit until 2003, during which time the 

tenant did not maintain the property and 

the buildings fell into poor condition. After 

2003, the buildings were vacant and became 

a target for illegal activities. During Valley 

Forge National Historical Park’s General 

Management Plan process, an internal 

management plan each park is required 

to develop, it was determined that there 

was no feasible use of the Farmstead for 

visitor services or park operations, and that 

adaptive use was an appropriate option.

At its own expense, MCHVF invested 

$3.8 million in rehabilitating the historic 

main house in accordance with the 

Secretary of the Interior’s Standards for the 

Treatment of Historic Properties. Following 

rehabilitation work, MCHVF opened its 

doors in February 2010 with six classrooms, 

a large multi-purpose room for gym and art, 

a meeting room dedicated for parents, two 

age appropriate playgrounds, and an athletic 

field. All future maintenance activities will 

be done in accordance with a maintenance 

and preservation plan approved by NPS.

Features of the project include the following:

» The main house being used for school 

meeting space and a residence for one 

teacher and family;

» A single-story addition to the barn for 

classrooms;

» Demolition of 1958 concrete-block 

buildings and construction of a 

parking lot, which is screened and 

not visible from either Valley Forge 

National Historical Park or a nearby 

neighborhood; and

» Reuse of the original driveway to the 

project to accommodate drop-off and 

pick-up of students.

In its rehabilitation of the David Walker Farmstead, the Montessori Children’s House of Valley 

Forge replaced the barn’s single story with a two-story wing to accommodate classrooms. 

CREDIT: NPS

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 41
Massachusetts, for several years to keep the building occupied and generate 

revenue needed to rehabilitate the building into office space for EPA and 

other federal tenants. USCG continues to operate its very successful historic 

lighthouse program, through which USCG maintains automated aids to navigation 

(navigation lights, foghorns) while making the historic lighthouses and/or keeper’s 

quarters themselves available to local governments and nonprofit organizations 

for interpretive, lodging, and other uses.

The United States Army Corps of Engineers used an enhanced use lease for a 

building within the Little Rock District to the City of Ozark, Arkansas, which 

nominated the building to the NRHP and now uses it as a community information 

center. It is clear however that leasing authorities, such as Section 111, cannot be 

uniformly implemented by all federal agencies. For agencies like the Department 

of the Treasury, all buildings in their inventory are in active use. And some agencies, 

like BOR, have buildings that are designed for such specific uses they cannot be 

easily adapted for others. However, even agencies with these limitations did report 

being aware of the authorities and were willing to use them when feasible.

COMMUNITY REVITALIZATION

The federal government contributes directly or indirectly to community 

revitalization through the historic buildings it owns, controls, manages, or leases. In 

spite of recent trends away from the symbolic federal presence in many places, 

characterized by the closure or relocation of postal facilities and the consolidation 

of offices and courts, there are still many opportunities for the federal government 

to contribute to local economies. EO 13006, “Locating Federal Facilities on Historic 

Properties in Our Nation’s Central Cities,” issued in 1996, directs agencies to 

“strengthen our Nation’s cities by encouraging the location of Federal facilities 

in our central cities.” Consistent with NHPA, agencies should also “provide 

leadership in the preservation of historic resources, and in the Public Buildings 

Cooperative Use Act of 1976 to acquire and utilize space in suitable buildings of 

historic, architectural, or cultural significance.” In September 2011, CEQ released its 

required “Implementing Instructions—Sustainable Locations for Federal Facilities” 

in accordance with Section 5(b) of EO 13514. Federal agencies are instructed 

to prioritze facility locations in central cities and rural town centers, focusing on 

the sustainable practice of co-location and mixed-use siting of federal facilities in 

central business districts and suburban/rural town centers. While these instructions 

were released at the end of the Section 3 reporting period, the ACHP anticipates 

that these instructions will inform federal agencies when establishing facilities, either 

through new construction or reuse of existing buildings within these locations.

There are numerous projects, large and small, underway at GSA facilities 

throughout the country that meet the letter and the spirit of EO 13006 and 

contribute to local economic development and opportunity. The oldest building 

in GSA’s portfolio, the Robert C. McEwen U.S. Custom House in Ogdensburg, 

New York (a Preserve America Community), was constructed in 1809-1810 for 

private use, then leased and later acquired by the government. A landmark on 

42 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
the Ogdensburg riverfront, it received a new lease on life and a new standing 

seam metal roof as a result of Section 111 procedures, providing upgraded 

facilities for Customs and Border Protection operations. The building celebrated its 

bicentennial in 2009.

A United States Geological Survey office in downtown St. Petersburg, Florida (a 

Preserve America Community), was established through a partnership with the 

University of Southern Florida and the St. Petersburg Downtown Partnership 

to renovate and reuse a historic Studebaker automobile dealership. The SPDP 

completed the renovation of the dealership to USGS specifications. Subsequently 

the USGS St. Petersburg Marine Science Center was renovated in consultation 

with the SPDP and the St. Petersburg Preservation Society, helping to fulfill EO 

13006 requirements. Similarly, a USGS Water Science Center in downtown Tacoma, 

Washington, which is leased through GSA, is housed in a renovated former Kress 

department store. When renovated for the new use, the outside historic façade 

and windows were retained along with the original 1929 Kress logo.

The Department of Labor has worked on a number of renovation projects for 

its Cincinnati Job Corps Center residential and career training facility in Cincinnati, 

Ohio. Originally built in 1897 by the Sisters of Mercy and used as a high school, 

several renovation projects have been completed to enhance the training and 

living environment at the center. A project completed in 2010 replaced the original, 

deteriorated windows and louvers with new insulated windows. Several students 

in the construction training program have been involved in the renovation work.

In 2011, the United States Postal Service transferred ownership of the Birmingham 

Post Office, Birmingham, Michigan, to a private developer with historic covenants 

to maintain three sides of the building allowing the fourth, or north/rear façade, to 

be converted into a new building entrance to provide direct public access into the 

main downtown commercial district. The private developer retained and restored 

the original clerestory skylights and maple wood floors. As part of the Shain Park 

Historic District, the rehabilitation of the building provides access onto a vibrant 

downtown retail district and meets the needs of the Birmingham real estate 

market. Currently, 10 companies lease space in the building.

In Atlanta, Georgia, with the help of a Save America’s Treasures grant, NPS is 

completing work on an $8 million renovation of the Ebenezer Baptist Church 

on Auburn Avenue, part of the Martin Luther King, Jr. National Historic Site. The 

complex and the National Historic Site, including the Visitor Center, the Birth 

Home, and the King Center, have provided a catalyst for significant revitalization 

in the Sweet Auburn neighborhood area of Atlanta. A second project that has 

been accredited with helping reverse decline in Atlanta’s historic downtown core 

and spurring preservation and reinvestment in adjacent neighborhoods is GSA’s 

recently completed rehabilitation of the Martin Luther King, Jr. Federal Building for 

its Southeast Regional Headquarters was recently awarded Leadership in Energy 

and Environmental Design Gold certification from the U.S. Green Building Council. 

This proactive protection and use of a historic asset received the ACHP Chairman’s 

Award for Federal Achievement in Historic Preservation in February 2012.

...the federal 

government can use 

its historic assets 

as catalysts for 

investment and largerscale community 

development in 

the surrounding 

area or adjacent 

neighborhoods.

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 43
The federal government has historically had a significant and symbolic presence 

in many community downtowns. Whether embodied in a local U.S. post office, a 

multipurpose federal office building, or a national park unit, the federal presence 

Downtown has a long history. When federal property managers recognize the 

important role these properties play in a community’s vitality and economic 

well-being and act to continue their contribution in changing times, the federal 

government can use its historic assets as catalysts for investment and larger-scale 

community development in the surrounding area or adjacent neighborhoods.

BUILDING PARTNERSHIPS

Agencies benefit from public-private and federal partnerships for the protection 

and use of federally owned and controlled historic properties, as they help 

leverage federal funds and staff to ensure effective stewardship. A few highlights of 

agencies’ use of partnerships include the following: 

» NPS leverages its operations with partnerships in all areas of management 

and at all levels of the organization to provide additional resources, encourage 

diversity of visitors and employees, and link communities and education 

institutions. The Volunteers-in-Parks Program saw 221,000 volunteers donating 

6.4 million hours of service to park units in 2010 for a total value of $133.4 

million. This program, with more than 370 volunteer programs throughout the 

NPS, has grown an average 5-7 percent annually since 1990.

» Treasury fosters an internal partnership between bureaus to exchange “best 

practices” to demonstrate and provide feedback on preservation projects. 

In addition, the Treasury Historical Association has provided Treasury with 

funding for preservation projects within the Main Treasury Building over the 

past three years resulting in the building maintaining its original appearance. 

The Treasury Historical Association has currently undertaken a capital 

campaign effort to fund additional projects in the future.

» FS Heritage Program reports approximately 30,000 Passport in Time (a 

Preserve American Steward) volunteers have donated 1.4 million hours at a 

total public value of more than $20 million.

» BLM reports partnerships are used for stabilization, interpretation, inventory, 

rehabilitation, curation, and site stewardship, augmenting the cultural resources 

management program’s budget between $2 and $3 million annually. Of all the 

volunteer hours provided to BLM, between 6 and 11 percent of those benefit 

the cultural resources program.

» USFWS has created successful partnerships with higher education institutions, 

non-profit organizations, and federal agencies. These include the following:

» Georgia Southern University in the discovery of Camp Lawton, one of the 

most intact Civil War archaeological sites found in decades, in 2010 at the 

Bo Ginn National Fish Hatchery and Magnolia Springs State Park, Georgia;

44 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
» Lewis and Clark National Historic Trail Heritage Foundation Manitou 

Bluffs Chapter and the Arrow Rock State Historic Site for the 

interpretation of the Jameson Island Unit at the Big Muddy National Fish 

and Wildlife Refuge, Missouri, through a Preserve America Grant; and

» NPS, in partnership with the Ounalashka Corporation, for the Lost 

Villages Project to document four Unangan Aleut villages in Alaska which 

disappeared in 1942 with the Japanese attack on Dutch Harbor, and the 

invasion of Attu and Kiska, and the U.S. government mandated evacuation 

of the Aleutian Islands, within the Alaska Maritime National Wildlife Refuge.

» USACE reports that without partnerships with the Kansas Archaeological 

Association, Kansas State Historical Society, and the University of Kansas in 

2011, the evaluation and mitigation of the Coffey Site at Tuttle Creek Lake, 

which is eroding due to natural causes, would not have been possible.

» The Maritime Administration has benefited from partnerships with nonprofit 

groups. A private nonprofit group provided the funding for the restoration of 

the Nuclear Ship Savannah’s original sofa in the ship’s main lobby, while MARAD 

restored the sofa’s structural foundation and elements of the main lobby.

» DOE’s Office of History and Heritage Resources has partnered with NPS 

to implement the Manhattan Project National Historical Park Study Act (P.L. 

108-340). The joint DOE/NPS study team looked at whether the historic 

properties at the three major Manhattan Project sites—Oak Ridge, Tennessee, 

Hanford, Washington, and Los Alamos, New Mexico—should be made part 

of the National Park System. In November 2009, a draft of the study was 

released to the public. In July 2011, the Secretary of the Interior, with DOE 

concurrence, recommended to Congress the establishment of a three-site 

Manhattan Project National Historical Park, with further recommendations 

that the park be managed as a partnership between NPS and DOE.

Agencies continue to report partnerships with Indian tribes to facilitate the 

identification, protection, and use of historic properties. Under the NHPA, federal 

agencies must consult with Indian tribes and Native Hawaiian organizations 

when carrying out federal actions. Where properly conducted, such consultation 

becomes the basis for long-term cooperative relationships. When it is not, agencies 

invariably face conflict and delay.

In 2008, the ACHP, recognizing the benefit of providing additional guidance to 

federal agencies and other stakeholders on consulting Indian tribes, published 

“Consultation with Indian Tribes in the Section 106 Process: A Handbook.” This 

guidance was developed primarily to aid federal agencies in consulting Indian tribes 

on a broad variety of issues relating to the federal preservation program, including 

their participation in efforts to identify, protect, and use historic properties in 

accordance with this EO.

Following this success, the ACHP published “Consultation with Native Hawaiian 

Organizations in the Section 106 Process: A Handbook” in 2011. Created by 

the ACHP’s Office of Native American Affairs, this handbook provides step-byCHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 45
step guidance for consulting with Native Hawaiian organizations when a federal 

undertaking may impact historic properties of religious and cultural significance to 

them. NHO consultation, mandated by NHPA and the ACHP’s regulations, often 

presents challenges for federal agencies and NHOs. This handbook clarifies the 

federal responsibility to consult with NHOs, and complements the 2008 tribal 

handbook, encouraging federal agencies to establish partnerships with these 

preservation partners. Both of these handbooks are available on the ACHP Web site.

MANAGING ASSETS

The 2011 progress reports demonstrate that challenges in addressing historic 

property management needs and issues related to development of business plans, 

ongoing facilities management, and capital improvement projects and programs 

remain. Many reports did note, however, that initiatives related to real property 

management (EO 13327) and sustainability (EO 13514) have had a positive 

effect on agencies’ abilities to manage historic properties. One of the most 

effective methods to protect historic properties is maintaining their productive 

use, evidenced by many agencies who reported the continued use of historic 

properties in their inventory.

Having substantially implemented the Integration of a Federal Legacy Vision with 

GSA’s Portfolio Strategy for Restructuring and Reinvesting in the Owned-Inventory by 

2008, GSA has moved to a more comprehensive core assets analysis by disposing 

of poorly performing properties within its inventory and focusing on maintenance 

and investment of its core assets. The Legacy Vision includes strategies for financially 

troubled historic buildings, with the goal of maximizing the number of historic 

buildings identified as core assets able to generate sufficient rental revenue to 

support their long-term maintenance and reinvestment. Under NHPA and EO 

13006, federal agencies are required to use historic buildings to the greatest extent 

possible and to give first considerations to locating government offices in historic 

properties. While GSA continues to struggle with tenant expectations and policy 

goals, maintaining occupancy of historic buildings is a priority, with the goal of 

keeping public buildings in public ownership. GSA uses historic buildings in five ways:

» Reinvest in them so they can serve the modern federal workforce;

» Reprogram them for new uses when necessary;

» Outlease them to private tenants when there is no immediate federal need;

» Lease them from nonfederal building owners;

» Acquire them to meet federal needs.

GSA encourages tenants submitting new space requests to consider reuse of 

historic buildings where achievable. GSA realty specialists play a crucial role in 

meeting these goals by working with tenants to think creatively about special 

needs and the unique qualities historic properties can provide. Through the use 

of feasibility studies, the sustainable action of reusing historic buildings can be 

properly evaluated as alternatives to new construction and disposal of historic 

buildings. Rising new construction costs and recent directives calling for agency 

use of government-owned space over leased space supports the use of structures 

One of the most 

effective methods 

to protect historic 

properties is 

maintaining their 

productive use, 

evidenced by many 

agencies who reported 

the continued use of 

historic properties in 

their inventory.

46 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
CASE STUDY

General Services 

Administration 

Reinvests 

Strategically to 

Sustain a Public 

Building Legacy

FEDERAL AGENCY 

General Services 

Administration 

LOCATION 

Nationwide

At the General Services Administration’s 

Public Buildings Service, business policy 

is based on tenant needs, urgency, fiscal 

soundness, community support, stewardship 

priorities, and other considerations–all 

conditioned on the quantitative criterion of 

acceptable return-on-investment. More than 

one-third of GSA’s 1,676 owned buildings are 

more than 50 years old, and more than onefourth of the inventory, 479 buildings, is listed 

in or eligible for the National Register of 

Historic Places. As caretakers of this sizable 

historic portfolio, GSA’s Center for Historic 

Buildings and Regional Historic Preservation 

Officers ensure stewardship strategies are in 

step with agency-wide business strategies.

GSA works to keep historic buildings 

occupied and in repair by investing 

strategically, drawing from multiple funding 

sources. Testament to GSA’s integrative 

planning, as well as the viability of their 

historic buildings, they invested $1.665 

billion–40 percent of the agency’s American 

Recovery and Reinvestment Act funding–on 

comprehensive modernizations and limited 

scope sustainability upgrades at 150 GSA 

historic buildings. Major modernization 

projects are underway at six courthouses; 

a 1931 custom house; three monumental 

federal buildings; and headquarters buildings 

for the Departments of Health and Human 

Services, Commerce, Interior, State, and 

GSA (Washington, D.C).

GSA also uses other innovative tools to 

fund preservation. The oldest building in 

GSA’s portfolio, the Customs and Border 

Protection-occupied Robert C. McEwen 

U.S. Custom House (Preserve America 

Community Ogdensburg, New York), a 

landmark on the St. Lawrence riverfront, 

received a new standing-seam metal roof 

using Section 111 funds. In addition, 

GSA’s historic properties are given 

additional weight for capital investment 

planning, using decision assisting 

software which considers many factors 

when comparing reinvestment options. 

GSA also utilizes reimbursable work 

authorizations, wherein tenant agencies 

fund improvements to their own facilities.

GSA continues to address technical 

challenges to historic preservation 

creatively. GSA has, and continues, to 

meet Administration sustainability and 

energy reduction goals by looking for 

opportunities throughout the building 

and site; creating envelope, system, and 

daylight management synergies; and 

reducing overall energy demand in historic 

buildings. Many limited scope projects, 

including heating, cooling, and lighting 

improvements, were addressed in a Section 

106 Program Comment tied to GSA’s 

Technical Preservation Guidelines, to 

streamline compliance and standardize 

submissions resulting in no adverse effect 

determinations. The Wayne N. Aspinall 

Federal Building and U.S. Courthouse 

(Grand Junction, Colorado) will be GSA’s 

first net zero historic building. Work was 

also finished at the John W. McCormack 

U.S. Post Office and Courthouse (Boston, 

Massachusetts), GSA’s first historic 

Leadership in Energy and Environmental 

Design Gold building rehabilitation, and 

the award-winning Martin Luther King, Jr. 

GSA’s 2011 Section 3 Progress Report, Extending the Legacy, summarizes progress made in 

the identification, protection, and use of historic properties. 

CREDIT: GSA

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 47

CONTINUED >>>
CASE STUDY | General Services Administration Reinvests 

Strategically to Sustain a Public Building Legacy (continued)

Federal Building (Atlanta, Georgia), a 

LEED Gold rehabilitation, received 

the Advisory Council on Historic 

Preservation Chairman’s Award for Federal 

Achievement in Historic Preservation in 

February 2012.

In 2009, GSA released new illustrated 

guidelines, Lobby Security in Historic 

Buildings, which provides guidance for 

layout, equipment placement, and detailing 

to minimize adverse effects associated 

with security processing activities. GSA 

also honors public access commitments 

by hosting public events at its buildings, 

and incorporating public access as Section 

106 mitigation. Specifically, in 2010, GSA 

worked with the Alabama State Historic 

Preservation Office to open their Freedom 

Riders Museum in the historic Montgomery 

Greyhound bus terminal, acquired as part 

of an adjacent courthouse expansion. GSA 

is also finalizing an agreement with the 

National Museum of Civil War Medicine, 

which will allow them to open the Clara 

Barton Missing Soldiers Office Museum in 

downtown Washington, D.C.

GSA’s Center for Historic Buildings 

considers its triennial Preserve America 

reporting requirement as an opportunity 

to promote successes, identify emerging 

issues, and engage GSA business lines in 

supporting stewardship strategies. GSA’s 

report, Extending the Legacy, can be 

found on the GSA Web site, with color 

illustrations, hyperlinks, and videos.

48 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
within the federal government real property inventory. GSA has long recognized 

that proper care of historic properties depends not only on technical competence 

of staff but also on the availability of funding to maintain and reinvest in historic 

properties. Accordingly, GSA’s overall strategy focuses first on use and second on 

the appropriate care of historic buildings.

FS acknowledges that not all historic properties share the same significance or 

reuse potential. Accordingly, the agency manages those properties in a manner 

that will maximize the public benefit. In doing so, the Heritage Program has 

developed criteria to identify Priority Heritage Assets that are or should be actively 

maintained in the FS real property inventory. The designation of a historic property 

as a Priority Heritage Asset means it is a heritage asset of distinct public interest.

In FY 2011, the Armed Forces Retirement Home drafted a 10-year Capital 

Improvement Plan for its two campuses in Gulfport, Mississippi, and Washington, 

D.C. The agency’s Cultural Resources Manager participated in all phases of the 

development of the plan and was engaged throughout the planning and drafting 

phases. This plan captures anticipated capital improvements through FY 2021. 

Historic Preservation and Stabilization is one of five agency programs that will be 

supported and implemented through these capital improvements, and specifically 

eight (17 percent) of the 47 projects are proposed for the Washington, D.C. campus.

NPS reported that since its 2008 progress report, the number of units in the 

National Park System has risen from 387 to 395, covering more than 84 million 

acres in 49 states, the District of Columbia, and U.S. territories. By using the 

Asset Priority Index and Facility Condition Index, park units determine project 

funding eligibility for assets in “good” or “fair” condition. Repair and rehabilitation 

funding is generally applied to facilities in “poor” condition. The Cyclic Maintenance 

for Historic Properties program is used for the preservation and stabilization 

of historic properties. It provides the means to accomplish park maintenance 

activities that occur on a fixed cycle longer than once in two years. This program is 

managed at the NPS regional office level and incorporates a number of regularly 

scheduled preventive maintenance procedures and preservation techniques into a 

comprehensive program that allows NPS to effectively manage historic properties. 

In FY 2010, NPS spent $19.7 million on cyclic maintenance projects.

Other successes noted in progress reports were the following:

» The rehabilitation of a NPS building within the Golden Gate National 

Recreation Area-managed area of the Presidio of San Francisco NHL by the 

National Oceanic and Atmospheric Administration for its Ocean Climate 

Center in 2010;

» The restoration of the patio at the American Merchant Marine Museum, Kings 

Point, New York, by MARAD in 2011;

» NPS stabilization of six Pearl Harbor bungalows at the World War II Valor in 

the Pacific National Monument in Honolulu, Hawaii; and

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 49
» The Department of Justice received a national award, from Masonry 

Construction Online, in 2010 for the preservation of a masonry smoke stack 

at United States Penitentiary Lewisburg, Pennsylvania.

Three agencies reported the use of Recovery Act funding to successfully manage 

historic properties:

» GSA successfully undertook modernization and sustainability upgrades at 150 

historic buildings with $1.665 billion;

» NPS rehabilitated the John Nelson House at Minute Man National Historical 

Park, Massachusetts; and

» FS rehabilitated the Keller Cabin in the Mendocino National Forest, California.

Many agencies reported on the growing volume and cost of deferred maintenance 

of historic properties. While continuing to manage historic properties, agencies 

often struggle to fund and implement regular condition assessments of historic 

properties in their inventory. Despite these challenges, numerous agencies 

reported successes in managing historic properties.

» On a scale of 1 to 10, with 10 being excellent, the condition of historic 

properties within the real property inventory of the Department of Health 

and Human Services was rated 7.5.

» Since 2008, FS has raised the number of Priority Heritage Assets managed to 

standard to just over 50 percent (3,389 of 6,747 total Priority Heritage Assets 

as of July 2011).

» During an annual condition assessment of all NASA buildings and structures, 

historic properties average 3.5, on a five point scale, while NASA properties 

overall averaged 3.3. NASA reports that 94 percent of its historic properties 

are currently being used.

» NPS reports 57.4 percent of historic properties are in good condition.

» BLM instituted a new performance measure in 2007 which set yearly goals 

for the percentage of properties in good condition; BLM met this goal with 49 

percent in 2008, 2009, and 2010.

Agencies reported on improvements managing historic properties in order to 

meet the sustainability goals of EO 13514. For example, GSA is developing federal 

facility location policy refinements, extending the historic city center preference 

for location of federal offices to include historic town centers and main streets. 

GSA also achieved its first LEED Gold rating for the rehabilitation of the John 

W. McCormack U.S. Post Office and Courthouse in Boston, Massachusetts. Work 

is currently underway for GSA’s first net zero historic building at the Wayne N. 

Aspinall Federal Building and U.S. Courthouse in Grand Junction, Colorado.

FS has identified historic properties as a key part of a new era of energy 

conservation and sustainable technologies. As historic buildings are identified for 

50 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
rehabilitation, FS evaluates their suitability for incorporation of sustainable energy 

technologies. The renovation of the Koen Building at the Ozark-St. Francis National 

Forest, Arkansas, has kept the historic fabric intact and brought the building up 

to current accessibility standards and building codes. An addition designed to 

resemble the original building was certified LEED Gold in July 2010.

Other agencies are including sustainability considerations into individual projects 

wherever possible. BOR’s Pacific Northwest Region, in partnership with the 

Bonneville Power Administration, modernized lighting in two of the historic 

power plants at Grand Coulee Dam, Washington, earning an EPA “Champions of 

Environmental Leadership and Green Government” award in 2010. And Treasury 

reported it was retroactively seeking LEED Existing Building certification for its 

1996-2006 renovation of the Main Treasury Building, and in fact was certified LEED 

Gold in December 2011. It is believed to now be the oldest building to achieve 

Gold certification. In addition, EPA reports a developing relationship with a private 

utility company to install and operate an electricity-producing solar plant at the 

NRHP-eligible Edison Laboratory Facility in Edison, New Jersey, in a manner that 

will not adversely affect the historic property.

With tight federal budgets, many agencies reported challenges managing historic 

properties due to limited resources for rehabilitation work and maintaining cultural 

resources staff. In BOR’s Lower Colorado Region, the Southern Nevada Public 

Land Management Act funding, which is generated from the sale of federal land, is 

expected to significantly decrease due to a drop in land sales associated with the 

sharp decline in the southern Nevada housing market. This loss of funds will have a 

direct effect on the rehabilitation and interpretation efforts at the Hoover Dam NHL.

Several agencies reported challenges reconciling their existing inventories with 

current and future mission needs. For agencies whose missions are technical in 

nature, such as NASA and HHS, continued use of older buildings and structures 

in their inventories may only be feasible if they are adaptable to evolving 

technologies. However, agencies such as Treasury have reported successfully using 

updated technologies in a compatible way with historic properties. This potential 

tension between old and new was also addressed by GSA, who reported on the 

increasing competition between contemporary workspaces in new construction 

and build-to-suit scenarios in adaptively reused historic buildings.

INTEGRATING STEWARDSHIP INTO AGENCY PLANNING

The 2011 progress reports demonstrate progress by the reporting agencies in 

the stewardship of historic properties and strengthening of their preservation 

programs. However, it is also evident that many agency strategic plans do not 

include stewardship goals at the agency level. Given the emphasis on a sustainable 

federal government, including a sustainable real property inventory, integrating 

stewardship into agency planning provides federal agencies with the knowledge 

and tools needed to reach the goals established in EO 13514.

With tight federal 

budgets, many 

agencies reported 

challenges managing 

historic properties due 

to limited resources 

for rehabilitation 

work and maintaining 

cultural resources staff.

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 51
For the first time in the Tennessee Valley Authority’s history, it will be developing 

a Cultural Resources Management Plan to establish program goals for the 

identification, evaluation, and protection of historic properties. In May 2008, 

the TVA Board of Directors approved a TVA Environmental Policy and 

the development of a Natural Resource Plan, to include cultural resources 

management, to commit itself to a more systematic and integrated approach to 

managing stewardship. The CRMP will be a component of the Natural Resource 

Plan to establish a baseline for historic property conditions and status and 

set goals for future management of those identified properties. Programs will 

include archaeological monitoring and protection, preservation, EO 13287, and 

archaeological outreach. It is anticipated that TVA will complete the CRMP by the 

next Section 3 progress reporting cycle, and future progress reports will be guided 

by and include activities with the Natural Resource Plan and the CRMP.

FS reported the Forest Service Manual 2360, Heritage Program Management. 

FSM 2360 continues to provide greater consistency across the FS on all levels 

through the standardization of policy directives that promote protection through 

adaptive use of historic properties. The policy guidance ensures that all Heritage 

Program staff work toward a common goal of promoting efficient and effective 

management of all heritage resources maintained by FS. FS has also developed 

an annual update to the National Heritage Strategy: It’s About Time. These updates 

assign priorities to specific Heritage Program leaders, develop training and 

workforce succession planning, and identify sustainable operation potential. 

Successes of the Heritage Program in the past three years include the following:

» Use of the previously reported Infra database Heritage Module. This 

module has enhanced and streamlined the process of identification and 

monitoring heritage assets as supported by the National Heritage Information 

Management Initiative.

» Development of the “Heritage Program Managed to Standard.” This internal 

performance measure accurately shows and reflects the direction of FSM 

2360 with seven new indicators facilitating precise tracking of all heritage 

assets managed by the Heritage Program. This new measure creates metrics 

by which the strengths and weaknesses of the Heritage Program at the 

regional and National Forest levels can be monitored more closely.

The progress report submitted by NASA provided information on a primary 

NASA Policy Directive that is further expanded through policy memoranda or 

requirements known as NASA Procedural Requirements. Further directives are 

then provided through handbooks that provide detail on processes and practices. 

The NPD for environmental management (which includes historic preservation) 

is NPD 8500.1. In 2009, NASA issued an Interim Directive (NM 8500-80) which 

specifically addresses cultural resource management. In 2011, NASA completed 

an NPR for Master Planning which will direct Master Planners to align specific 

Master Plans with Sections 106 and 110 and emphasize reuse of eligible facilities. 

While NASA does not have distinct policies that distinguish between identification, 

protection, and use of historic properties, the same policies identified through 

52 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
CASE STUDY

Bureau of Land 

Management’s 

Renewable Energy 

Efforts

ENTITY 

Bureau of Land Management 

LOCATION 

Western U.S.

In recent years the Bureau of Land 

Management has built a comprehensive 

renewable energy program to address the 

large number of renewable energy projects 

proposed by private entrepreneurs for 

placement on BLM-managed lands. Among 

other initiatives, the Energy Policy Act of 

2005 established a goal for the BLM to 

approve a minimum of 10,000 megawatts of 

non-hydropower renewable energy on BLM 

lands by the year 2015. The agency has also 

responded to the Administration’s emphasis 

on developing solar, wind, and geothermal 

resources, and ensuring the appropriate 

transmission of that energy to the locations 

where it is needed.

Environmental compliance under the 

National Environmental Policy Act 

and the National Historic Preservation 

Act’s Section 106 process on renewable 

energy-related proposals constitute a 

significant responsibility for the agency. 

BLM has created a range of internal 

teams and procedures–as well as joined 

interagency efforts–to ensure efficient, 

effective consideration of these proposed 

projects. The Department of the Interior 

and BLM annually defines a list of priority 

projects in order to focus resources on 

the utility-scale projects that have a high 

potential for success rather than addressing 

proposals on a first come, first served 

basis. BLM took a hard look at “lessons 

learned” from 2010 energy projects and 

developed detailed new guidance that 

requires pre-application meetings with 

project proponents and guides field staff 

in screening applications. BLM hosts 

weekly national conference calls, which 

include representatives of agencies such 

as the Advisory Council on Historic 

Preservation (ACHP) and the U.S. Fish 

and Wildlife Service, in order to monitor 

progress on priority projects in the 

NEPA and Section 106 processes. BLM’s 

NEPA Review Strike Team ensures 

that priority project documents receive 

both immediate and concurrent review 

by a team of Washington, D.C. Office 

specialists. BLM and the ACHP also 

participate in the Renewable Energy Rapid 

Response Team and Rapid Response Team 

for Transmission, which work to facilitate 

interagency coordination and cooperation 

on energy projects. Together the ACHP 

and BLM created the Western Energy 

and Historic Preservation Workgroup to 

ensure that historic preservation values 

are considered efficiently in energy project 

planning and implementation.

Reviewing and approving large-scale 

energy projects challenged BLM’s capacity 

in terms of knowledge as well as workload. 

BLM has taken steps to increase capacity 

by establishing Renewable Energy 

Coordination Offices within state and 

local BLM offices in those areas with 

a high demand for renewable energy 

projects and by adding personnel where 

needed, including cultural resource 

specialists. There have been concerted 

efforts to increase understanding, such 

as offering a Renewable Energy Summit 

to communicate across the organization 

the importance of this issue, providing 

additional training for managers and 

specialists, and creating an active 

renewable energy Web site for the agency 

and external parties, including applicants.

Wind farm in Oregon

CREDIT: ACHP

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 53

CONTINUED >>>
CASE STUDY | Bureau of Land Management’s Renewable 

Energy Efforts (continued)

BLM and the Department of Energy are 

preparing a joint NEPA Programmatic 

Environmental Impact Statement 

to evaluate utility-scale solar energy 

development on BLM-managed lands in 

six western states. BLM, serving as the 

lead federal agency, plans to establish Solar 

Energy Zones on lands within Arizona, 

California, Colorado, New Mexico, Nevada, 

and Utah that are best suited for utilityscale production of solar energy. To meet 

its Section 106 responsibilities for this 

undertaking, BLM is consulting on a 

Programmatic Agreement that lays out 

the process for completing Section 106 on 

project- specific proposals within the SEZs 

as proponents submit applications to use 

BLM-managed land.

Since at least 2005 the BLM has focused 

on renewable energy issues and how 

to accomplish the ambitious goals set 

by the Administration. The agency has 

thoughtfully addressed the capacity and 

communications issues over time, resulting 

in a comprehensive and effective renewable 

energy program.

54 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
NPD 8500.1, NM 8500-80, and individual internal reporting methods at each of 

the NASA Centers through Integrated Cultural Resources Management Plans, 

support the use of historic properties and provide a foundation for revitalization 

and stewardship.

At GSA’s Public Buildings Service, the agency’s business policy is based on 

tenant needs, urgency, fiscal soundness, community support, and other practical 

considerations conditioned on the quantitative criterion of acceptable return-oninvestment. GSA’s national preservation program is collaborating with regional 

preservation staff and asset management teams to develop Regional Action Plans 

focused on identifying and implementing turnaround strategies for at-risk legacy 

buildings. Concurrently, GSA is working to protect the federal government’s 

leasehold interests. In 2010, GSA updated its Portfolio Reinvestment and Asset 

Repositioning Strategy focused on long-term customer needs, market location 

strength, financial performance, and the condition of each building. This GSA 

strategy provides a good model for integrating stewardship of historic properties 

into overall agency planning.

Within the Treasury each organization is encouraged to use information recording 

systems that work best for their specific needs. This decentralized approach is 

also embraced at BOR, where offices develop location or activity-specific plans 

for inventory and evaluation as needed. BOR did report that since FY 2008 it 

has finalized a new Directive and Standards to define internal cultural resources 

management requirements, reviewed and updated three policy statements 

(Cultural Resources Management (LND P01), Museum Property Management

(LND P05), and Museum Property Management (LND 02-02)), and finalized a 

new Directive and Standard, Operations and Maintenance of Project Works that are 

Historic Properties (LND 02-03).

Because cultural resources are included in USFWS strategic planning, several 

reporting requirements, specifically for performance, including a Refuge Annual 

Performance Plan (which includes the number of historic buildings in good 

condition), are under the purview of a Regional Historic Preservation Officer. In 

FY 2010, USFWS revised and updated its 614 FW chapters 1-5 which provides 

policy for compliance with NHPA and coordination with NEPA and 126 USFWS 

chapters 1-3 which provides policy for the USFWS museum property program. 

New versions are expected to go into effect in FY 2012.

Several agencies reported on the staffing levels and expertise which supports 

stewardship requirements. FS employs approximately 350 archaeologists, historians, 

and other heritage specialists in permanent positions. USACE staff includes more 

than 150 historic preservation specialists from various disciplines and provides 

training in enforcement of laws related to the protection of historic properties. 

USFWS has 22 full-time cultural resource employees, with each region employing 

at least one cultural resource specialist who meets the Secretary of the Interior’s 

Professional Qualification Standards. It routinely provides hands on training 

opportunities to its staff. NASA requires that Historic Preservation Officers at 

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 55
each Center have training in Section 106 compliance. And BOR has 39 cultural 

resources management staff located in 21 offices throughout the western U.S.

Several agencies reported on specific programs and initiatives that support their 

respective preservation programs, including the following:

» NPS’s Cultural Resources Preservation Program which provides funds for 

security, environmental control, and other concerns for museum collections, and 

for the inventory, urgent stabilization, and preservation of historic properties.

» Department of Homeland Security Environmental Planning and Historic 

Preservation Committee, which shares information and best practices among 

the historic preservation practitioners within DHS.

» GSA’s use of a Section 106 program alternative, the Program Comment 

on Select Envelope and Infrastructure Repairs and Upgrades to Historic 

Public Buildings, to encourage GSA project teams to pursue alternatives that 

minimize or avoid adverse effects on historic buildings during Recovery Act 

projects and beyond.

» BLM’s engagement of the public in the development of master leasing plans 

prior to making a commitment to lease or develop an area. This includes areas 

where a substantial portion of federal lands are unleased, where a moderate 

or higher potential for oil and gas exists, and where additional analysis or 

information is needed to address likely resource or cumulative impacts if oil 

and gas development were to occur.

» MARAD’s requirement for the number of heritage assets to be reported to 

the Chief Financial Officer on a quarterly basis.

» HHS’s Facility Condition Assessment, which results in information being 

consolidated into its Real Property Asset Management Plan.

» The Bureau of Indian Affairs is developing a Web-based preservation plan for 

contributing resources within the Fort Washakie Historic District, Wyoming, 

on the Wind River Indian Reservation. This interactive tool assists the local 

facility manager to determine the appropriate methods to maintain the 

historic character of historic properties.

Three agencies, BLM, BOR and USACE, reported a specific correlation between 

the protection of historic properties and planning activities at their agency. For 

example, of the 60,000-plus historic properties managed by USACE, more than 

75 percent are archaeological sites. Through its planning mechanisms, USACE 

strives to keep the location of these sites confidential in order to ensure their 

protection. BOR protects historic properties in its stewardship through a number 

of mechanisms, including public education to increase the understanding of the 

value and vulnerability of resources, integrating cultural resources management 

into management planning and design efforts, site monitoring, and sensitive design 

or modifications to historic buildings and structures. And BLM continues to work 

to increase the number of historic properties covered by proactive protection 

Proactive management 

of historic properties 

through identification, 

protection, and use 

results in a working 

knowledge of 

historic properties 

and comprehensive 

inventories that 

support agency 

missions and allows 

the Section 106 

process to be a tool 

in transparent federal 

decision making.

56 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
measures. Between FY 2007 and FY 2010, the number of protected sites increased 

by 10 percent.

Several agencies cited compliance with Section 106 was an example of integrating 

stewardship into agency planning. However, proactive management of historic 

properties through identification, protection, and use results in a working 

knowledge of historic properties and comprehensive inventories that support 

agency missions and allows the Section 106 process to be a tool in transparent 

federal decision making.

In 2011, the ACHP revised its Section 3 Advisory Guidelines to encourage federal 

agencies to report on compliance with EO 13514. There is a direct correlation 

between sustainability and preservation, evidenced by federal agencies who are 

integrating sustainability into their strategic plans. NPS has created the Sustainable 

Operations and Climate Change Branch, within the Park Facility Management 

Division to assist park units in implementing sustainable best practices. In 2011, 

a Cultural Resources Climate Change Adaptation Coordinator was hired to 

coordinate policy and activities surrounding adaptive management of resources 

ahead of climate change impacts.

BOR has structured its sustainability program to work closely with staff in the 

Property and Design and Construction programs to ensure integration of historic 

preservation planning and sustainability requirements. NASA’s SSPP (required 

by EO 13514) encourages adaptive reuse. It has created an internal Cultural 

Resources Management Panel and will integrate cultural resources into its 

Environmental Management System. The Sustainable Policy Handbook for Facilities 

identifies the need to include historic preservation within an integrated design 

approach through all stages of project planning and delivery. BLM is advancing 

several projects that are models of sustainable management practices. These 

projects incorporate creative reuse of existing properties, energy efficiencies, and 

long-term, self-sustaining partnerships.

In September 2011, CEQ released its “Implementing Instruction—Sustainable 

Locations for Federal Facilities” in accordance with EO 13514. There are 

four principles for sustainable federal locations including one principle that 

acknowledges reuse of previously developed sites benefits communities, reduces 

sprawl, and reduces the need for new construction and development. This 

principle specifically promotes the preservation of historic resources and other 

existing buildings. Starting with the June 2012 SSPP update, federal agencies are 

required to report on how they have integrated the four principles in their SSPP.

DHS has created an executive-level sustainability working group to advance its 

plans for addressing sustainability and mission responsibilities, all in accordance with 

existing DHS policy and guidance. And GSA is meeting energy reduction goals 

in historic buildings by looking for opportunities throughout the building and site, 

creating envelope, system, and daylight management synergies, and reducing overall 

energy demand.

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 57
ENHANCING AND IMPROVING INVENTORIES OF 

HISTORIC PROPERTIES

In 2006, the ACHP found that agencies lacked accurate, comprehensive 

information regarding their historic property assets. However, the now mandatory 

data element of historic status code required for reporting to the FRPP has 

proven to be a successful tool for federal agencies to improve real property 

inventories of historic properties. While the focus of agency reporting continues 

on the identification of buildings and structures as real property, it is important 

to consider and evaluate other historic property types as agencies continue 

to enhance and improve the overall inventory of historic properties. These 

include archaeological sites, cultural landscapes, and sites of religious and cultural 

significance to Indian tribes.

Agencies report significant progress in establishing internal policies and directives 

in the identification of real property, resulting from EO 13327 and the FRPP. For 

example, BIA has adopted the historic status codes of the FRPP to categorize its 

buildings in its Facilities Management Information System. Many agencies reported 

continued improvement in existing policies and directives. Information provided 

indicates the agencies are also improving their inventories of more diverse historic 

property types. The majority of historic property identification reported by 

agencies was the result of compliance with the Section 106 process. It is important, 

however, for agencies to also establish procedures for proactive identification 

efforts under Section 110 of NHPA. Not only is Section 110 a statutory 

requirement, but it can assist agencies in the management of historic properties 

and streamline the Section 106 compliance process. The Secretary of the Interior’s 

Standards and Guidelines for Federal Agency Historic Preservation Programs 

Pursuant to the National Historic Preservation Act provides federal agencies with 

seven standards and associated guidelines to meet the Section 110 requirement.

Several agencies did report on improvements in the identification of historic 

properties. A sample of improvements in agencies identifying historic properties 

includes the following:

» NASA identified a total of 259 new buildings and structures that were 

determined eligible for listing on the NRHP and identified 192 archaeological 

sites. As a result of this increased inventory, it has increased its historic 

property inventory by more than 100 percent.

» BLM made significant progress with more than 2.5 million acres inventoried; 

an increase of more than 30 percent over the previous reporting cycle. This 

survey resulted in the identification of numerous historic properties, an 

increase of 40 percent over the previous reporting cycle.

» MARAD evaluated 36 vessels and determined that seven were eligible for the 

NRHP.

» BOR reported that by the end of FY 2010, 12,097 individual properties and 

81 historic districts were inventoried (with 1,395 properties found to be 

58 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
contributing to those districts) and 1,055 individual properties were assessed 

for eligibility to the NRHP. An estimated 1,611,862 acres were surveyed.

» The Department of Veterans Affairs completed NRHP nominations for five 

individual medical centers since 2008. These include the medical centers at 

San Francisco, California (a Preserve America Community); American Lake, 

Washington; Columbia, South Carolina (a Preserve American Community); 

Mountain Home, Tennessee; and Hot Springs, South Dakota.

» DOJ has completed determinations of eligibility on five facilities managed by 

the Federal Bureau of Prisons that were found eligible to the NRHP: Federal 

Prison Camp Alderson, West Virginia; USP Lewisburg, Pennsylvania; Federal 

Medical Center Lexington, Kentucky; Federal Correctional Camp Lompoc, 

California; and Medical Center for Federal Prisoners Springfield, Missouri.

» USGS has initiated a survey to evaluate its inventory of real property for 

eligibility to the NRHP. This critical survey started in 2011 and by the end of 

2012, it is anticipated that 13 facility evaluations will be completed.

» A number of agencies under DHS have reported progress in their efforts 

to identify historic properties. The Federal Law Enforcement Training Center 

has met a goal to document and provide information to the general public 

about its historic property inventory at its Glynco, Georgia, campus. USCG is 

nearing completion of a survey to identify and evaluate all remaining USCG 

lighthouses. And CBP has set a goal to inventory one-third of all property 

each year until completed.

In addition to these accomplishments, a number of new initiatives were reported 

by agencies:

» BOR continues to develop broad historic context studies to be used agencywide. These context studies facilitate the evaluation of properties for eligibility 

to the NRHP in a cost effective manner, reducing the amount of propertyspecific research needed to meet documentation requirements. Between FY 

2008 and 2010, the Policy and Administration Office completed and published 

The Bureau of Reclamation’s Civilian Conservation Corps Legacy: 1933-1942

which summarizes the history of all BOR’s Civilian Conservation Corps camps.

» As its inventory continues to age, NASA is shifting its focus from using NRHP 

Criterion Consideration G (a property achieving significance within the past 

50 years if it is of exceptional importance) to evaluate properties, to applying 

the standard NRHP Criteria for Evaluation.

Many agencies reported using existing reporting requirements, such as the 

development of an Asset Management Plan required by EO 13327 and the 

Secretary of the Interior’s Report to Congress on the Federal Archaeology Program, 

as a framework for historic property reporting. Several agencies report that they 

are working to use such government-wide reporting requirements for real property 

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 59
and historic properties into internal reporting requirements for the identification and 

evaluation of historic properties. These efforts include the following:

» BOR’s Federal Preservation Officer now receiving the historic status codes 

assigned under the FRPP.

» From 2008 to 2011, NASA reported implementing its “Environmental Tracking 

System” to centralize reporting on its cultural resources and uploaded 259 

historic buildings and structures into its real property database, updating the 

historic status codes for reporting under EO 13327.

» MARAD and the Federal Aviation Administration use DOT’s Real Estate 

Management System to collect and report data in accordance with EO 13327.

» Data gathered by NOAA’s Integrated Facilities Inspection Program allows the 

agency to prioritize which properties should be further studied and evaluated 

for eligibility to the NRHP.

Many agencies provided information on the funding mechanisms for historic 

property inventories within their agency. For example, at BLM, the majority of 

inventory work was funded by land use applications and associated fees, and the 

work was performed by consultants for more than 700 applicants permitted 

by BLM. NPS Alaska Region, partnering with USFWS, received a grant from the 

American Battlefield Protection Program to document U.S. and Canadian World 

War II sites on Kiska Island within the Alaska Maritime National Wildlife Refuge. 

Two agencies reported the use of funds received through the Recovery Act to 

expand their inventories. CBP used the funding for the identification and evaluation 

of Land Ports of Entry. USACE reported that funds were used for Section 110 

compliance projects in its Northeast, Southeast, and Western regions. In less than 

18 months the following was completed by USACE using Recovery Act funding:

» Total acres surveyed: 76,000

» Sites identified: 929

» Site revisited: 601

» Sites tested for NRHP eligibility: 42

» Sites considered eligible for NRHP listing: 453

» Sites considered not to be eligible: 428

» Sites requiring further evaluation: 48

Numerous challenges were reported by agencies in the identification of historic 

properties. Limited agency budgets and competing missions were the most cited 

reasons for incomplete inventories of historic properties. Those agencies with 

preservation mandates as part of their mission (e.g. NPS, BLM) found it easier to 

budget for historic property identification than those agencies whose missions 

were not preservation driven, such as BOR and DHS. Still, even those agencies 

with preservation mandates frequently report that budgets are insufficient for the 

management of their massive property holdings, and the use of funds for historic 

property studies and evaluations are often minimal.

60 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
CASE STUDY

Closure of Fort 

Monroe, Virginia 

and Creation of 

a New National 

Monument

ENTITY

National Park Service and the 

Fort Monroe Authority 

LOCATION 

Hampton, Virginia

President Barack Obama created the Fort 

Monroe National Monument in November 

2011, by exercising his authority under 

the Antiquities Act. There are currently 

21 national park units located in Virginia; 

Fort Monroe is the 22nd and the 396th 

nationwide. This new national monument is 

comprised of 325 acres.

In 1609 after the founding of Jamestown, 

Virginia, settlers built a fortification called 

Point Comfort which later became Fort 

Monroe at the confluence of the James River 

and the Atlantic Ocean. The first enslaved 

Africans were brought to this geographic 

location in 1619 which was the beginning 

of slavery in North America. During the 

Civil War, after General Benjamin F. Butler 

declared any runaway slave “contraband of 

war,” Fort Monroe became the recipient 

of the first freed fugitive slaves. This 

action by General Butler, instrumental 

in the formulation and execution of the 

Emancipation Proclamation by President 

Abraham Lincoln, signaled the end of 

slavery in the U.S. These important events 

in U.S. history along with the intact nature 

of the buildings and landscape of Fort 

Monroe, under the careful stewardship 

of the Department of the Army, were the 

foundation for the designation of this new 

national monument.

Encompassing approximately 570 acres, 

Fort Monroe, including the last moatencircled active Army installation, the Old 

Point Comfort Lighthouse, the former 

Chamberlin Hotel, and 189 other historic 

properties, was recognized as a historic 

“crown jewel” in the Army inventory. When 

the decision was made to close Fort Monroe 

as an active Army installation under the 

Base Realignment and Closure Act of 

2005, many local and national groups with 

interests ranging from history to natural 

resources and proponents for the fort’s 

future use participated in the Section 106 

process. The transfer to the Commonwealth 

of Virginia was completed in September 

2011, and is currently controlled by the 

Fort Monroe Authority on behalf of the 

Commonwealth. The Army will continue to 

operate the Casement Museum located at 

Fort Monroe.

A grass roots effort in favor of a national 

monument designation began at the local 

level several years ago. Local and state 

governments and nonprofit organizations 

worked together with the National Trust 

for Historic Preservation to request a 

National Park Service presence at Fort 

Monroe. According to Secretary of the 

Interior Ken Salazar “President Obama has 

ensured that this historic fort, a symbol of 

the long struggle for freedom for African 

Americans, will be preserved as a national 

park for generations to come.”

The FMA Reuse Plan estimates that Fort 

Monroe will be an incubator of 3,000 jobs. 

With NPS involvement it is estimated for 

every dollar invested, four additional dollars 

will be generated. This infusion of new 

jobs in the Commonwealth as well as the 

investment represented by a NPS presence 

represents how an important historic and 

natural asset can contribute to a local and 

regional economy.

Fort Monroe, Virginia 

CREDIT: FORT MONROE AUTHORITY

CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP | 61
SUMMARY

The 2011 progress reports received by the ACHP on federal agency efforts 

to identify, protect, and use historic properties continue to show improvement 

and are demonstrative of the concerted efforts many agencies are making 

to manage properties in accordance with the goals of NHPA and EO 13287. 

While many challenges remain and new opportunities are emerging, the ACHP 

notes significant progress in the development of public-private and federal 

partnerships and the inclusion of non-federal stakeholders in the consideration 

of these stewardship issues.

62 | CHAPTER 3—CURRENT STATE OF FEDERAL STEWARDSHIP
Chimney Rock is a San 

Juan National Forest 

Archaeological Area located 

in Colorado between 

Durango and Pagosa 

Springs. The 118 prehistoric 

sites within the area were 

created by the people of the 

Chacoan culture, ancestors of 

contemporary southwestern 

Puebloan people. The 

Chimney Rock Interpretive 

Association was designated 

a Preserve America Steward 

in 2009.

CHAPTER 4: FINDINGS 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 is the 2011 progress reports submitted by federal 

agencies, the ACHP has been informed by its extensive interaction with federal 

agencies and preservation partners in day to day activities. In addition to the 

information federal agencies provided on the identification, protection, and use of 

historic properties, the ACHP is aware of a number of issues in the management 

of historic properties that will require new strategies for their effective stewardship 

that were not directly reported by federal agencies. It is clear that these issues have 

had, and will continue to have, a broad effect on property managing agencies in the 

coming years.

The 2011 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 management protocols, procedures, and 

other tools. Agencies have acknowledged that strategies for the management of 

one property type or even one very specific property may not be applicable to 

others, and the original uses of historic properties, especially those of a scientific 

CREDIT: FS
nature, produce obstacles in adapting them to current needs. While most agencies 

have tools and procedures at their disposal that are sufficiently diverse to prepare 

them for most anticipated management challenges, many agencies continue to be 

presented with obstacles that cannot be effectively addressed by current business 

models or standard federal practices. The ACHP will continue encouraging federal 

agencies to review their policies and procedures for the identification, protection, 

and use of historic properties to ensure they are adequate to respond to evolving 

and emerging preservation and management issues.

While many agencies are improving the management and condition of their 

historic property inventory, others continue to approach historic preservation as a 

collateral responsibility, separate from and not adequately integrated into strategic 

plans for meeting core missions. Along with ongoing efforts to ensure federal 

real properties are mission critical, sustainable, and energy efficient, the federal 

government should strive to further develop a stewardship ethic that recognizes 

the preservation, enhancement, and productive use of agency historic properties 

as sustainable.

The 2011 progress reports continue to demonstrate that historic preservation 

initiatives that involve partnerships with non-federal entities can bring significant 

social and economic benefit to both agencies and local communities. While 

many agencies have more fully embraced partnerships with state, tribal, and local 

communities and the private sector, there is ample opportunity to expand these 

partnerships, and there remains a demonstrated desire by local communities to 

engage further in heritage tourism and local economic development initiatives 

with federal agencies. Awareness of and appreciation for the value of priceless 

resources under federal ownership will foster better management practices that 

will benefit these agencies, the American people, and the historic properties 

themselves.

The following findings and recommendations demonstrate priorities the ACHP 

will address to further improve the federal preservation program and respond 

to emerging issues in the management of historic properties for the next agency 

reporting cycle in 2014.

FINDING NO. 1: ECONOMIC DEVELOPMENT AND JOB 

CREATION

While federal agencies and the historic properties under their ownership or 

control have great potential to contribute to local economic development through 

job creation, public-private partnerships, property management practices, and 

participation in local and regional heritage tourism initiatives, they have not 

systematically done so.

As found in 2009, many federal agencies have made efforts to develop publicprivate partnerships that support the protection and use of historic properties. 

However, few indicate that these efforts are guided by policies or strategic goals 

that support broader preservation goals in their agency. In addition, few agencies 

64 | CHAPTER 4—FINDINGS AND RECOMMENDATIONS
were able to calculate or otherwise determine the local or regional economic 

impact of public-private partnerships, visitation related to heritage tourism at 

federally owned historic properties or nearby non-federal sites, effects on local 

tourism tax revenues, community property values, or the impact on related service 

industries or job creation. Recent studies on the economic impacts of Civil War 

battlefield preservation, National Wildlife Refuge visitor programs, and parks 

and open space have also indicated important contributions to local economies. 

However, these initiatives directly correlate with agencies whose missions include 

protection and enhancement of historic resources and visitation and use by the 

public, most notably NPS, BLM, FS, and USFWS. A number of agencies have found 

creative ways to promote heritage education and tourism programs, despite the 

lack of obvious connection with their principal missions. In particular, agencies like 

NOAA and NASA have advanced educational experiences that draw visitors to 

their facilities and help support the local economy. DOE also has done this to 

some extent within the limits of their security and mission needs, most actively 

through museums outside facility boundaries.

The investment of federal resources in partnerships with local communities to 

identify, protect, and use historic properties can often spur economic development 

in gateway communities, urban environments, and inner cities where a strong 

federal presence has traditionally supported communities in the past. Often 

agencies that have determined a need to reduce their property holdings in such 

areas fail to consider the benefits of retaining assets that might be good candidates 

for public-private partnerships or cooperative heritage tourism programs. With 

the exception of GSA, which has prepared its own disposal guidance, most 

agencies have not developed protocols for considering the value of reusing historic 

properties for these purposes as part of the disposal process.

Recommendations

» The ACHP should collaborate with federal agencies and relevant private 

sector organizations to provide federal agencies with more information, 

guidance, and models on the economic value of federal historic property 

stewardship, including the potential contributions of federal historic properties 

to local economic development. The ACHP should integrate any guidance 

provided into future Section 3 advisory guidelines for agency use.

» Federal agencies should employ standard methods and the systemic collection 

of data based on a uniform set of metrics for measuring the direct and indirect 

economic impacts of historic preservation (including heritage tourism) at the 

state, regional, and local levels that can be applied nationally. The DOC should 

take the lead to advance this effort, collaborating with the ACHP, individual 

federal agencies, state and local government, and private sector entities 

(including academic institutions) that have previously supported work in this area.

The investment of 

federal resources in 

partnerships with local 

communities to identify, 

protect, and use 

historic properties can 

often spur economic 

development in gateway 

communities, urban 

environments, and 

inner cities where a 

strong federal presence 

has traditionally 

supported communities 

in the past.

CHAPTER 4—FINDINGS AND RECOMMENDATIONS | 65
FINDING NO. 2: SUSTAINABILITY

Agencies would benefit from guidance on the advantages of retaining and converting 

historic buildings and structures into sustainable properties that meet the goals of 

the Energy Independence Security Act of 2007 and EO 13514, as well as guidance 

on promoting the development of a sustainable federal infrastructure that recognizes 

the economic and environmental value of retaining historic properties.

Congress and the Administration continue to advocate for a federal government 

and workforce that reduces energy consumption and increases energy efficiency. 

In 2009, President Obama issued EO 13514 specifically targeting the reduction 

of greenhouse gas emissions, energy intensity in buildings, and use of fossil fuels 

and the increase in use of renewable energies by the federal government. This 

EO, along with several initiatives pending before Congress, has focused significant 

attention on agency efforts to decrease energy consumption.

As noted in 2009, agencies faced with meeting these standards must assess the 

energy efficiency and performance of current property holdings to determine 

whether existing infrastructure meets the goals established by EISA or whether 

buildings would be considered under-performers in need of retrofitting, 

rehabilitation, or disposal. EO 13514 has reinforced this requirement through 

the mandate for agency SSPPs. Many agencies still lack a clear awareness of 

sustainability benefits of historic buildings. As a result of this misconception 

regarding the retention value and energy efficiency potential of older buildings, 

some agencies continue to pursue disposal of older, underperforming buildings 

to make way for new inventory. The perceived higher cost of retrofitting 

or converting older buildings into energy efficient buildings that meet goals 

established by EISA and EO 13514 may also serve as a deterrent for retaining 

these buildings.

However, historic buildings and facilities 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 in 

the past. They were also typically constructed to be responsive to local climates. 

Frequently the higher quality construction materials used in their construction 

support modern energy efficiency goals and relatively long life cycle use.

Agencies should consider the strong reinvestment potential in historic buildings 

and structures, which are often built to better standards and, once renovated, are 

strong performers. Agencies should also factor in the inherent energy already 

imbedded in these buildings and the potential environmental cost of disposing of 

these materials. With limited federal budgets, agencies will need to rely on both 

new construction and rehabilitation of existing historic properties in order to meet 

the mandates of EISA and EO 13514.

CEQ in its “Implementing Instructions—Sustainable Locations for Federal Facilities,” 

developed and released in accordance with EO 13514, has outlined four principles 

for agencies to integrate into their annual SSPP update starting in June 2012. One 

of the four principles encourages agencies to maximize the use of existing resources, 

66 | CHAPTER 4—FINDINGS AND RECOMMENDATIONS
specifically promoting the preservation of historic resources and other existing 

assets. In light of these new principles, it is likely that federal agency strategic plans 

developed in the coming years will reflect an increased emphasis on adaptive reuse 

of existing assets, rather than new construction. The ACHP will consider updating 

the Section 3 advisory guidelines for future reporting to explore how federal 

agencies integrate the sustainable federal locations principles into the SSPPs.

Agencies are increasingly turning to the standards developed by the U.S. Green 

Building Council for guidance on energy performance improvements. To date, 

LEED has primarily focused on new construction; LEED metrics that value and 

measure embodied energy life cycle and durability of historic buildings, materials, 

and systems have been unavailable. However, in 2010, the USGBC initiated an 

effort to update the LEED rating system, and the ACHP encouraged federal 

agencies to follow its lead and provide comments on the draft’s implications for 

the preservation of historic properties. Since many federal agencies are utilizing 

the LEED rating system, the proposed revisions will have direct impacts on agency 

stewardship of historic buildings. It is expected that this effort will be completed 

in 2012.

In addition, in 2011, the ACHP prepared guidance to advise federal decision 

makers regarding the requirements of Section 2(g) of EO 13514. The ACHP 

developed the guidance to assist federal agencies in their efforts to meet the 

expectations of the EO while also meeting the requirements of NHPA. The 

goal of the guidance is to assist federal decision makers, usually capital asset 

managers, facility managers, and other program and project managers in their 

considerations regarding sustainability and historic federal buildings. The decision 

makers will benefit from the ACHP’s recommended strategies to consider 

historic preservation along with energy efficiency and sustainability concerns, to 

seek out historic preservation outcomes, and to take advantage of opportunities 

for meeting historic preservation and energy efficiency and sustainability goals 

together in the administration of federal buildings.

It is clear from the 2011 progress reports and other interactions with federal real 

property managing agencies, however, that little internal guidance is available within 

federal agencies on how to transform the existing infrastructure into a greener 

and energy efficient one while recognizing the environmental benefit of retaining 

historic properties in the process.

Agencies have demonstrated that many of their historic buildings and structures 

are built to high structural standards and have correspondingly long expected 

life cycles, and that they can easily become better energy performers through 

the application of new technologies that improve usability and energy efficiency 

without routinely requiring the replacement of historic fabric. While these 

technologies are widely known and applied in the private sector, many federal 

agencies have not developed or provided guidance to their facility managers 

on the application of these standards to historic buildings, and often do not 

provide funding for the upfront investment required to convert these into better 

performers and provide a return on this initial investment over the long term.

While usability and 

energy efficiency 

technologies are widely 

known and applied 

in the private sector, 

many federal agencies 

often do not provide 

funding for the upfront 

investment required to 

convert existing assets 

into better energy 

performers.

CHAPTER 4—FINDINGS AND RECOMMENDATIONS | 67
Recommendations

» CEQ’s Steering Committee on Federal Sustainability (established in accordance 

with EO 13514) should collaborate with the ACHP to provide guidance on 

the benefits of adapting historic properties to meet sustainability goals and 

considering potential effects to historic properties related to disposal.

» GSA’s Green Buildings Advisory Committee (established in accordance with 

EISA) should collaborate with the ACHP to provide guidance on the benefits 

of adapting historic properties to meet sustainability goals and considering 

potential effects to historic properties related to disposal.

» The ACHP and NPS should continue to advocate for acknowledgement of 

the durability of historic buildings, materials, and systems in order to provide 

needed encouragement for the reuse of historic properties during USGBC’s 

LEED update process.

» Agency SRPOs, SPOs, and SSOs (required by EO 13514) should meet to 

discuss procedures to ensure that buildings and structures being considered 

for rehabilitation or disposal to meet energy efficiency and sustainability goals 

are subject to a complete evaluation, taking their historic significance into 

account. The ACHP will work with DOI, OMB, and the RPAC to coordinate 

such a meeting. Any findings or recommendations resulting from this meeting 

will be shared with SPOs, SRPOs, SSOs, the public, and the private sector.

FINDING NO. 3: RENEWABLE ENERGY

Renewable energy initiatives present the opportunities for the preservation 

community to think creatively about resource stewardship and management in 

the current economic climate but also have the potential to significantly impact 

historic properties.

The ACHP is actively addressing the implications of renewable energy 

development and transmission on historic properties through a variety of 

groups and interagency forums. The ACHP is participating in a number of 

Administration initiatives, including CEQ’s Rapid Response Teams on Renewable 

Energy, Energy Transmission, Transportation, and Priority Infrastructure Projects 

resulting from the August 2011 Presidential Memorandum, the Bureau of Ocean 

Energy Management’s Smart from the Start Initiative, and the development of 

a Memorandum of Understanding regarding offshore wind development in the 

Great Lakes, as well as on- and off-shore wind energy development forums to 

ensure federal planning properly addresses preservation interests.

The Western Renewable Energy and Historic Preservation Workgroup, jointly 

established in 2009 by the ACHP and DOI, through BLM, is addressing issues of 

cultural resource protection that are emerging in large-scale energy development 

and transmission projects proposed on BLM lands in the western U.S. While 

these projects are being managed through the regular Section 106 process, the 

workgroup reviews progress, addresses common issues that emerge from the 

68 | CHAPTER 4—FINDINGS AND RECOMMENDATIONS
individual reviews, identifies topics where additional education and awareness 

would benefit stakeholders, and compiles “lessons learned” to guide future energy 

development projects in the western U.S. and elsewhere. These may include 

approaches to resource identification, avoidance and mitigation, and consultation 

with stakeholders.

In response to the heightened interest in renewable energy issues, the ACHP 

launched a dedicated subpage on the ACHP’s Web site focused on renewable 

energy development, including information, tools, guidance, and contacts. In 

addition, in January 2011 the ACHP and the National Association of Tribal 

Historic Preservation Officers, in cooperation with NPS, convened a Tribal 

Summit on Renewable Energy in Palm Springs, California. The Summit provided 

an unprecedented opportunity for tribal leaders and federal officials to address 

the broad implications of renewable energy development and transmission on 

historic properties and also underscored the importance of focusing on the 

impact on historic properties of a number of renewable energy projects slated for 

development by BLM. These impacts are being addressed through the WREHPWG.

Tribal Summit participants also encouraged the ACHP and NPS to address long 

standing issues related to the treatment of large traditional cultural landscapes 

through the Section 106 process. Recognizing the potential for renewable 

energy development and federal development of all kinds to continue impacting 

landscape level resources, the ACHP co-sponsored a forum along with NPS on 

traditional cultural landscapes in Seattle, Washington, in August 2011. In response 

to this forum, the ACHP has developed a Native American Traditional Cultural 

Landscapes Action Plan, which was adopted by the ACHP membership at its 

November 2011 business meeting.

Recommendations

» Federal agencies should continue to identify opportunities for efficiencies and 

streamlining to complete the Section 106 compliance process for renewable 

energy projects. In order to ensure that federal planning for renewable energy 

development successfully incorporates historic preservation requirements 

early in project planning, the Administration and individual agencies should 

engage the ACHP and other agency preservation resources in interagency 

environmental streamlining and stewardship initiatives on renewable energy, 

such as the Renewable Energy Rapid Response Teams, Priority Infrastructure 

Projects, and on- and off-shore wind initiatives.

» The ACHP and NPS should collaborate with development agencies and 

stakeholders to address longstanding issues related to the treatment of large 

traditional cultural landscapes through the Section 106 process. 

» NPS should continue its commitment to revise Bulletin 38: Guidelines for 

Evaluating and Documenting Traditional Cultural Properties, and collaborate 

with the ACHP to ensure the revised guidance is responsive to the 

CHAPTER 4—FINDINGS AND RECOMMENDATIONS | 69
challenges presented to the protection of historic properties by renewable 

energy development.

FINDING NO. 4: FEDERAL REAL PROPERTY 

REALIGNMENT

Agencies face a significant challenge in the realignment of real property portfolios, 

balancing stewardship responsibilities and mission needs.

Congress and the Obama Administration have continued to advance initiatives 

that would mandate federal agencies to reduce their property holdings to only 

those essential to meet agency missions. In June 2010, President Obama issued 

a memorandum for the disposal of unneeded federal real estate with a target of 

$3 billion in cost savings by the end FY 2012. As part of the FY 2012 budget, a 

legislative proposal (known as CPRA) was introduced, and OMB has established 

an RPAC to identify strategies for minimizing waste and the efficient disposal of 

federal real property.

Many federal agencies that have identified non-essential or “under-performing” 

property are confronted by the prospect of disposing of large numbers of 

buildings, facilities, and structures no longer critical to agency missions. Many 

of these properties are heritage assets and historic properties. Excess acreage 

may also contain archaeological sites, cultural landscapes, or other properties 

of religious or cultural significance. The disposal of federal properties presents 

unique challenges to agencies who must balance budgetary and management 

priorities, identify mission-critical assets, and determine how non-critical assets can 

be removed from ongoing management. Agencies report that many methods of 

disposal (donation, sale, transfer to other federal, state, tribal, or private entities, 

leasing, and demolition) are all utilized on a case-by-case basis to reduce unneeded 

property holdings. For most agencies, however, this reduction process is not 

influenced by the properties’ historic significance or potential for reuse based 

upon its unique characteristics as a historic property. As a result, agencies often 

dispose of properties absent any strategic policy that recognizes the historic value 

of some properties for retention or reuse.

Many agencies face mandates to reduce property holdings as part of a “footprint” 

or inventory reduction. However, the historic value of a property or its suitability 

for reuse is only considered after disposal decisions have already been made. Few 

agencies have strategic plans that encourage consideration of these values prior to 

a disposal decision and in decision making. Although traditionally excess properties 

are buildings and structures, in many instances historic districts, cultural landscapes, 

archaeological sites, traditional cultural properties, and even ships are included 

among these “at risk” historic properties. Following years of deferred maintenance 

and neglect, agencies may conclude that the cost of repair, rehabilitation, or 

retrofitting is financially prohibitive. As a result, demolition or site clearance is 

often considered the best alternative for agencies to redevelop or transfer cleared 

parcels free of restrictions.

70 | CHAPTER 4—FINDINGS AND RECOMMENDATIONS
Several agencies, including DHS and NASA, report significant restrictions on the 

use of public-private partnerships or leases for alternate uses for non-mission 

critical property due to security issues and concerns. For many agencies, excess 

property may be located within secure perimeters or is adjacent to other 

federal property that must remain in governmental control and secure from 

outside threat. In these circumstances, alternative uses for properties subject to 

abandonment and/or disposal are severely limited. Agencies also report challenges 

adapting highly technical or scientific facilities for reuse. And properties that were 

classified as “temporary” when they were constructed (and were therefore often 

built to lower standards) are often considered less desirable for long-term reuse 

by public or private partners. Similarly, ubiquitous property types or designs 

within agencies may be targeted for abandonment or disposal and present reuse 

challenges for partners who may have limited interest or ability to reuse multiple, 

similar properties.

It is clear that agencies with comprehensive historic property surveys of their real 

property holdings are able to more effectively manage their inventories. Yet many 

agencies continue to report that, despite incremental progress in identifying historic 

properties, they continue to lack a comprehensive understanding of their inventory, 

and historic significance has typically not been fully evaluated. Agencies report 

ongoing financial and administrative challenges in managing underutilized or nonmission critical properties, including a shortage of funding to conduct identification 

and evaluation efforts for these properties, and insufficient qualified personnel 

to perform the work. These challenges are increasing as agencies’ inventories 

continue to age and must be identified and evaluated for eligibility to the NRHP. 

Most agencies report insufficient allocation of resources to conduct inventories 

outside the Section 106 process. As a result, many agencies depend solely on the 

identification efforts conducted through the Section 106 compliance process. This 

reactive approach limits an agency’s ability to comprehensively understand their 

resources and establish an effective management strategy for their stewardship.

Section 111 of NHPA allows agencies to reinvest lease proceeds for historic 

preservation activities involving the subject property or other historic buildings. 

However, few agencies’ legal offices recognize the authority of Section 111 or 

consider it sufficient legal authorization within their establishing legislation, mission, 

and performance measures. By using Section 111 authority, agencies have the 

opportunity to access a new revenue source and fund projects that may not have 

previously been considered a funding priority.

Section 412 of the General Provisions Consolidated Appropriations Act 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’s cost 

for the entire lease term to be financed up front in the first year of the lease. 

This treatment has limited GSA’s ability to use private financing to leverage the 

equity value of government assets. Greater flexibility with the application of 

budget scoring rules to outlease/leaseback transactions made pursuant to Section 

Typically located in 

town or city centers 

and near other 

important properties, 

prominent public 

buildings in federal 

ownership, including 

monumental buildings 

such as courthouses, 

custom houses, and 

agency headquarters, 

remain profoundly 

important symbols of 

federal stewardship 

and community pride.

CHAPTER 4—FINDINGS AND RECOMMENDATIONS | 71
412 leases would facilitate GSA’s ability to keep these important federal public 

buildings occupied and viable.

Federal agencies that own iconic historic buildings report they have experienced 

limitations in their ability to fund the repair and alteration necessary to ensure 

these buildings remain occupied and viable. Often considered to be the most 

recognizable and prominent public buildings in federal ownership, these structures 

include monumental buildings such as GSA-owned courthouses, custom houses, 

and agency headquarters, as well as other federally owned administrative buildings, 

post offices, residences, and health care facilities, most of which were constructed 

to high architectural standards and with widely recognizable artisanship. Typically 

located in town or city centers and near other important properties, these 

buildings remain profoundly important symbols of federal stewardship and 

community pride.

It is the clear goal of Congress and the Administration to reduce the role of 

the federal government as “property manager,” particularly when maintaining 

properties with no mission critical requirement. This goal is reasonable; however, 

the federal government is steward of diverse properties that represent America’s 

tangible and intangible history. This trust responsibility, on behalf of the American 

public, must be taken seriously, and agencies should seek ways to meet disposal 

goals while protecting irreplaceable assets. By fully implementing legal authorities, 

like Section 111 and Section 412, federal agencies can maintain historic properties 

without federal appropriations, making them financially self-sufficient.

Recommendations

» OMB, in consultation with GSA, the ACHP, and other affected agencies, should 

re-examine the application of Section 412 scoring rules as applied to historic 

buildings and pursue changes to facilitate the outlease of important federal 

historic buildings.

» The ACHP, GSA, and NPS should collaborate to encourage federal agencies 

to use existing federal leasing and reuse authorities, including Section 111 and 

Section 412, to promote the use of federal historic properties to promote 

economic development.

» The FRPC should extend observer status to the ACHP so that the two 

organizations may collaborate on the development of agency disposal 

plans that recognize the value and potential reuse of historic properties in 

their portfolios.

» The ACHP and OMB’s RPAC should work together to provide guidance on 

potential effects to historic properties to the RPAC.

» The ACHP should advise Congress and the Administration on the implications 

of CPRA on historic properties and encourage proper integration of historic 

preservation considerations and values.

72 | CHAPTER 4—FINDINGS AND RECOMMENDATIONS
FINDING NO. 5: FEDERAL AGENCY PRESERVATION 

PROGRAMS IN THE 21ST CENTURY

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 at the appropriate level. As 

a result, many agencies find it difficult to identify adequate resources to effectively 

resolve conflicts between NHPA and other statutory requirements.

The ACHP noted in 2009 that historic preservation rarely rises to the level of 

inclusion in an agency strategic plan; yet doing so would improve the ability of real 

property management agencies to manage historic properties as assets, rather 

than confront them as obstacles to implementing other mission priority programs 

and projects. The Section 3 progress reports continue to indicate that agencies 

are incorporating historic preservation management responsibilities required 

by Section 110 into strategic plans at the individual program or sub unit level; 

however, many agencies still do not tie these to broader property management 

goals nor do they develop performance measures and measure whether progress 

has been made at the headquarters level. The absence of historic preservation 

components in agency- or bureau-wide property management plans that would 

provide direction on the identification, protection, and use of historic properties 

continues to relegate the stewardship of these properties to a lower status and 

hinder cultural resource management staff from achieving the goals of this EO.

While there has been steady improvement in agencies reporting on the 

identification, protection, and use of historic properties within their inventories, the 

information remains incomplete as agencies improve various reporting systems 

and find ways to fully meet their Section 110 responsibilities. With the exception 

of those reports submitted by agencies with large land holdings, most agency 

reports do not consistently address archaeological sites, cultural landscapes, and 

properties of religious and cultural significance to Indian tribes.

Several agencies reported using Section 106 as the primary means to protect 

historic properties. While avoidance of adverse effects to historic properties is a 

protection measure, Section 106 is often initiated too late in the decision making 

process, when avoidance is no longer viable. Because agencies must comply with 

numerous environmental laws and regulations, it is important that they develop 

a compliance strategy that gives equal weight to all statutory considerations. The 

regulations implementing Section 106 of NHPA provide a planning process that 

is intended to be a venue to discuss alternatives to avoid, minimize, or mitigate 

potential effects with identified stakeholders. But in order for this process to be 

most effective, Section 106 must be initiated early in the project planning process. 

When used effectively Section 106 can be a powerful tool to federal agencies in 

making sound decisions regarding real property management.

Consistent with the requirements of EO 13563, “Improving Regulation and 

Regulatory Review,” and the Administration’s push for a more streamlined federal 

review process, the ACHP completed its review of the regulations implementing 

Section 106. Based on its analysis and public comments received, the ACHP 

CHAPTER 4—FINDINGS AND RECOMMENDATIONS | 73
adopted a plan for completing this and future reviews in August 2011. The ACHP 

finds that the current Section 106 regulations are not outmoded, ineffective, 

insufficient, or excessively burdensome, and therefore should not be modified, 

streamlined, expanded, or repealed. However, in the interest of the ACHP and the 

public to seek continuous improvements to the Section 106 regulatory process, 

and consistent with the ACHP’s 2011 Strategic Plan, the ACHP has committed 

to issue guidance and provide education, training, and outreach to support the 

effective participation of consulting parties and the public in the Section 106 

process and to promote the effective consideration of historic preservation 

requirements in federal planning. This includes using the Section 3 progress reports 

as a mechanism to gather data from federal agencies and periodically report on 

the adequacy and effectiveness of their preservation programs in carrying out the 

requirements of Section 106.

EO 13287 calls for the designation and active participation of SPOs in the 

development of historic preservation management procedures that will advance 

the goals of this EO in each agency. Typically these officials serve as an assistant 

secretary or deputy assistant secretary who assists in the development of agency 

budgets. Their incorporation into the preservation planning process is designed to 

ensure that agencies establish effective plans and priorities for meeting these goals 

and that agency budgets support the achievement of these plans. It has become 

clear to the ACHP, however, that some agencies have reassigned SPO designation 

to officials who do not meet the requirements of the EO and who lack sufficient 

planning and budgetary authority to adequately influence or address systemic 

historic preservation issues at the policy level.

In order to maximize the effectiveness of SPOs, designation of an SPO at 

the assistant secretary or deputy assistant secretary level or its bureau level 

to coincide with the SRPO and SSO designations could help ensure that 

consideration is given to the development of agency-wide strategic plans for the 

effective management of historic properties.

The ACHP notes that several federal agencies with significant inventories of historic 

properties did not submit progress reports as required by the EO, or submitted well 

after the September 30 deadline. The EO serves to encourage agencies to manage 

their historic properties consistent with the requirements of NHPA and furthers 

the Administration’s goals of efficient management and use of federal resources and 

sustainable infrastructure. Effective compliance with the EO and pursuit of its goals 

can help advance important Administration policies and initiatives.

Recommendations

» All real property managing agencies should designate an SPO that meets 

the standards of Section 3(e) of EO 13287. The ACHP should continue to 

encourage and assist agencies in meeting this requirement.

It is the clear goal 

of Congress and the 

Administration to 

reduce the role of the 

federal government 

as “property manager,” 

particularly when 

maintaining properties 

with no mission 

critical requirement.

74 | CHAPTER 4—FINDINGS AND RECOMMENDATIONS
» All federal agencies should designate an FPO in accordance with Section 

110(c), and in support of Section 3(e) of EO 13287. The ACHP and NPS 

should continue to encourage and assist agencies in meeting this requirement.

» The ACHP and CEQ should complete guidance on the coordination of 

reviews under Section 106 and NEPA consistent with Section 800.8 of the 

ACHP’s regulations.

» Consistent with the goals of the ACHP 2011 Strategic Plan and EO 13563, 

the ACHP should 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 regulations.

» NPS should review and revise as necessary the Secretary of the Interior’s 

Standards for the Treatment of Historic Properties, and collaborate with the 

ACHP to ensure that the revised guidance is responsive to the challenges of 

protecting historic properties.

» The Administration should reaffirm the purpose and intent of EO 13287 and 

encourage federal agencies with real property responsibilities to submit the 

required progress reports to the ACHP and the Secretary of the Interior.

SUMMARY

Federal agencies are encouraged to support the ACHP in meeting these 

recommendations as they examine their preservation programs to determine how 

they can improve their stewardship of historic properties and productively use 

their historic property inventories. Few agencies reported on the establishment 

of specific, measurable goals for improving their efforts to identify, protect, and 

use historic properties. Agencies are encouraged to devise such plans and use 

these metrics to report on their progress in addressing these challenges and 

implementing these recommendations in 2014, the next reporting cycle.

CHAPTER 4—FINDINGS AND RECOMMENDATIONS | 75
Students from Philadelphia, 

Pennsylvania, take part in an 

archaeological dig as part 

of their Save Our History 

project on the grounds of a 

former Underground Railroad 

stop at what is now the 

historic Johnson House site. 

CHAPTER 5: TOWARD A 

COMMON GOAL

EO 13287 REQUIRES THAT EACH AGENCY with real property 

management responsibilities develop triennial reports on its 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. These progress reports 

are vital to the improvement of federal historic property management. They assist 

the ACHP and the Administration in measuring the progress and commitment 

by agencies in achieving the goals of this EO by supporting the ACHP’s ability to 

report triennially on the state of the federal government’s historic properties and 

their contribution to local economic development.

The 2011 Section 3 progress reports represent the fourth round of reporting 

by federal agencies under EO 13287 and continue to demonstrate a clear 

commitment to improve the stewardship of historic properties. Agency reports 

provide information on historic property inventories in accordance with the goals 

of NHPA and EO 13287, and demonstrate the commitment to integrate principles 

of sustainability into property management consistent with current Administration 

initiatives. While many challenges remain and new challenges emerge, the ACHP 

notes significant progress in the development of public-private partnerships and 

the inclusion of non-federal stakeholders in the consideration of stewardship issues.

As federal agencies strive to carry out their responsibilities under Section 110 of 

NHPA and develop comprehensive inventories of these properties in the 21st 

century, many are identifying properties with more diverse areas of significance 

CREDIT: SAVE OUR HISTORY / 

HISTORY®
than ever before. Due to the passage of time, many historic properties, like those 

associated with the terrorists attacks of September 11, 2001, are significant as a 

result of modern events that have become embedded in the country’s collective 

memory. This evolution of significance requires agencies to think broadly when 

evaluating properties and identifying stakeholders. The launch of AGO and the 

Department of the Interior’s American Latino Heritage Initiative are just the start 

of such a wave to capture and maintain, for future generations, the knowledge of a 

shared story that is as important today as it was yesterday.

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. The Federal Property Management Section 

of the ACHP’s Office of Federal Agency Programs continues to work closely with 

federal property managers in meeting and improving their responsibilities under 

Sections 106 and 110 of NHPA. FPMS is integral to advancing the goals of this 

EO and providing assistance to stakeholders in meeting identified challenges. In 

Fiscal Years 2012 through 2014, the ACHP will continue to partner with property 

managing agencies, SPOs, FPOs, and agency leadership to identify opportunities for 

affording greater protection to historic properties under federal control. It will also 

seek new partnerships to support Administration initiatives that will advance the 

federal government’s identification, protection, and use of historic properties while 

meeting the goal of a clean energy economy and fiscal responsibility.

The issuance of EO 13287 has proven to be a useful tool for identifying the status 

of federal historic property management and the progress federal agencies have 

made in the management of real property. The first ACHP Report to the President 

represented a milestone in federal stewardship and provided the first opportunity 

for agencies to examine their own achievements and receive independent evaluation 

from the ACHP on these efforts. This third triennial report has demonstrated that 

federal property managers are using EO 13287 to strengthen their preservation 

programs and challenge their own leadership to meet these goals. The ACHP 

anticipates that the recommendations within this report, once implemented, will 

improve the efficiency and effectiveness of agency efforts to continue improving their 

stewardship of heritage assets and create a sustainable and efficient inventory.

There is no doubt the federal government faces unprecedented challenges in 

the next three years as it endeavors to reduce the size of its real property 

inventory, transform its remaining buildings into green, energy efficient assets, and 

utilize these assets to promote economic development and revitalization to the 

economy on a national, state, and local level. The retention of historic properties 

as energy efficient and strong performing assets can contribute to each of 

these goals and, in so doing, promote economic development and enhance 

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. These federal 

assets are American assets, and they are vital to maintaining a sense of history, 

belonging, and identity to all Americans.

The launch of 

America’s Great 

Outdoors and the 

Department of the 

Interior’s American 

Latino Heritage 

Initiative are just the 

start of such a wave to 

capture and maintain, 

for future generations, 

the knowledge of a 

shared story that is as 

important today as it 

was yesterday.

CHAPTER 5—TOWARD A COMMON GOAL | 77
CASE STUDY

Preservation Green 

Lab: A Nonprofit’s 

Contribution 

to Sustainable 

Development

ENTITY 

National Trust for Historic 

Preservation 

LOCATION 

Nationwide

The National Trust for Historic 

Preservation plays a vital role in the 

preservation of the nation’s historic places. A 

private, nonprofit membership organization 

dedicated to saving historic places to enrich 

America’s future, the NTHP advocates 

for preservation at the federal level and 

supports grassroots preservation nationwide. 

The NTHP’s Sustainability Program 

promotes the reuse and retrofit of existing 

buildings and reinvestment in communities 

through policy, research, and outreach. In 

March 2009, it launched the Preservation 

Green Lab, a think tank focused on 

sustainability and historic preservation, in 

Seattle, Washington, with the mission to 

further the scientific understanding of the 

value of the existing U.S. building stock. 

The PGL also develops and promotes 

strategic policies for integrating the 

reuse and retrofit of existing and historic 

buildings into government efforts to achieve 

sustainability objectives.

Recognizing that more than 40 percent of 

the nation’s carbon emissions come from 

the construction and operation of buildings, 

one of the PGL’s forthcoming studies 

illustrates that reusing and improving the 

efficiency of existing and historic buildings 

is an essential part of a clean energy 

economy. This study, entitled “The Greenest 

Building: Quantifying the Environmental 

Value of Building Reuse,” compares the 

environmental impacts of demolition 

and new construction to building reuse 

using Life Cycle Assessment. Life Cycle 

Assessment is an internationally recognized 

approach that evaluates the potential 

environmental and human health impacts 

associated with products and services 

throughout their life cycle. Specifically, 

the study aims to compute and compare 

the life cycle environmental impacts of 

buildings undergoing rehabilitation to those 

generated by the demolition of existing 

buildings and their replacement with new 

construction; determine which stage of a 

building’s life (i.e. materials production, 

construction, occupancy) contributes most 

significantly to its environmental impacts, 

when those impacts occur, and what drives 

those impacts; and assess the influence 

of building typology, geography, energy 

performance, electricity-grid mix, and life 

span on environmental impacts throughout 

a building’s life cycle.

This study assesses primary scientific life 

cycle impact data from six different building 

typologies (single family, multifamily, 

commercial, mixed-use, warehouse, and 

an elementary school) in four climate 

zones of the U.S. to address human 

health, ecosystem quality, climate change, 

resources, and water impacts. Preliminary 

results indicate that reuse is almost always 

more environmentally friendly than new 

construction, assuming comparable energy 

performance. Further, the PGL study shows 

new high performance buildings rarely 

“catch up” with retrofitted existing or historic 

buildings.

Many federal agencies have adopted 

sustainability goals and standards, issued 

by organizations including the U.S. Green 

Building Council and the American 

Society of Heating, Refrigerating, and 

Air Conditioning Engineers, which have 

affected historic buildings and structures. 

Warehouse Historic District, Cleveland, Ohio

CREDIT: NATIONAL TRUST FOR HISTORIC PRESERVATION

78 | CHAPTER 5—TOWARD A COMMON GOAL
Given PGL’s forthcoming groundbreaking 

scientific study quantifying the value of 

building reuse, as well as additional studies 

on green policies and best practices, the 

NTHP’s study will become a valuable 

resource for federal agencies striving to 

meet sustainability goals with underutilized 

existing and historic buildings.

Just as the ACHP advocated in its own 

private industry partnership publication 

with Booz Allen, Assessing Energy 

Conservation Benefits of Historic Preservation: 

Methods and Examples (1979), “The 

Greenest Building: Quantifying the 

Environmental Value of Building Reuse,” 

will provide a greater understanding of the 

potential environmental value associated 

with reuse and retrofitting existing and 

historic buildings. The study is expected 

to provide a valuable tool for federal 

decision makers to achieve sustainability 

goals for historic buildings in their 

inventories that were previously considered 

underperforming. Improving the efficiency 

of existing and historic buildings should 

become a critical element of every agency’s 

capital improvement plan, and a principal 

part of a sustainable federal future.

CHAPTER 5—TOWARD A COMMON GOAL | 79
APPENDIX A: EXECUTIVE 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 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 longterm 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 

80 | APPENDIX A—EXECUTIVE ORDER 13287, PRESERVE AMERICA
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 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 longterm 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, 

APPENDIX A—EXECUTIVE ORDER 13287, PRESERVE AMERICA | 81
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” 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.

82 | APPENDIX A—EXECUTIVE ORDER 13287, PRESERVE AMERICA
APPENDIX B: ADVISORY COUNCIL ON HISTORIC 

PRESERVATION MEMBERSHIP

Chairman

Milford Wayne Donaldson (California)

Vice Chairman

Clement A. Price (New Jersey)

Expert Members

Horace H. Foxall, Jr. (Washington)

Terry Guen (Illinois)

Dorothy Lippert (Washington, D.C.)

John G. Williams, III (Washington)

Citizen Members

Mark A. Sadd (West Virginia)

Bradford J. White (Illinois)

Member of an Indian Tribe

John L. Berrey (Oklahoma)

Governor

Vacant

Mayor

Hon. Michael B. Coleman 

(Columbus, Ohio)

Architect of the Capitol

Secretary, Department of the 

Interior

Secretary, Department of 

Agriculture

Secretary, Department of 

Commerce

Secretary, Department of 

Education

Secretary, Department of 

Defense

Secretary, Department of 

Transportation

Secretary, Department 

of Housing and Urban 

Development

Secretary, Department of 

Veterans Affairs

Administrator, General Services 

Administration

Chairman, 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 Homeland 

Security

Observer: Secretary, 

Department of Energy

Observer: Administrator, 

Environmental Protection 

Agency

Observer: Chair, National 

Alliance of Preservation 

Commissions

Observer: President, ACHP 

Alumni Foundation

APPENDIX B—ADVISORY COUNCIL ON HISTORIC PRESERVATION MEMBERSHIP | 83
APPENDIX C: ADVISORY GUIDELINES IMPLEMENTING 

SECTION 3: REPORTING PROGRESS ON THE 

IDENTIFIC ATION, PROTECTION, AND USE OF FEDERAL 

HISTORIC 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 April 

2011 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, however; and 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 AMPs 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 SSPPs 

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 (per 

Section 3(d)).

The following questions were asked in the 2011 

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.

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.

84 | APPENDIX C—ADVISORY GUIDELINES IMPLEMENTING SECTION 3
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 in 

accordance with EO 13514 and how these goals are 

being met, taking stewardship of historic properties 

into account.

APPENDIX C—ADVISORY GUIDELINES IMPLEMENTING SECTION 3 | 85
APPENDIX D: EXECUTIVE BRANCH AGENCIES’ 

COMPLIANCE WITH EO 13287

AGENCY 2004 baseline 

report filed

2005 progress 

report filed

2008 progress 

report filed

2011 progress 

report filed

Armed Forces Retirement Home ▲ ✔ ✔

Department of Agriculture ● ● ● ●

Agricultural Research Service ✔

Forest Service ✔ ✔ ✔ ✔

Farm Services Agency ✔ ✔

Natural Resource 

Conservation Service ■ ✔ ✔ ✸

Rural Development ✔ ✔ ✸ ✸

Department of Commerce ✔ ✔

National Oceanic and 

Atmospheric Administration ✔ ◆ ◆ ◆

Department of Defense ✔ ✔

United States Army 

Corps of Engineers ▲ ▲ ▲ ✔

Department of Education ✸ ✸ ✸ ✸

Department of Energy ✔ ✔ ✔

Department of Health 

and Human Services ✔ ✔ ✔ ✔

Department of Homeland Security ✔ ✔ ✔ ✔

Federal Law Enforcement 

Training Center ✔ ◆ ◆ ◆

Department of Housing 

and Urban Development ✔

Department of the Interior ● ● ● ●

Bureau of Indian Affairs ✔ ✔ ✔ ✔

Bureau of Land Management ✔ ✔ ✔ ✔

Bureau of Reclamation ✔ ✔ ✔

Fish and Wildlife Service ✔ ✔ ✔ ✔

National Park Service ✔ ✔ ✔ ✔

United States Geological Survey ✔ ✔ ■

Department of Justice ✔ ✔ ✔ ■

86 | APPENDIX D—EXECUTIVE BRANCH AGENCIES’ COMPLIANCE WITH EO 13287
Federal Bureau of Prisons ✔ ✔ ◆ ◆

Department of Labor ✔ ✔ ✔ ✔

Department of State ✔

Department of Transportation ● ● ● ●

Federal Aviation Administration ✔ ✔ ✔ ✔

Federal Highway Administration ✔ ✸ ✸ ✸

Federal Motor Carrier 

Safety Administration ✸ ✸ ✸ ✸

Federal Railroad Administration ✸ ✸ ✸ ✸

Federal Transit Administration ✸ ✸ ✸ ✸

Maritime Administration ▲ ✔ ✔ ✔

Surface Transportation Board ✔

Department of Treasury ✔ ✔ ✔

Bureau of Engraving and Printing ✔ ✔

Department of Veterans Affairs ✔ ✔ ✔ ■

Environmental Protection Agency ✔ ✔ ✔ ✔

Federal Energy 

Regulatory Commission ✔ ✔

General Services Administration ✔ ✔ ✔ ✔

National Archives 

and Records Administration ✔ ✔

National Aeronautics 

and Space Administration ✔ ✔ ✔ ✔

National Science Foundation ✸ ✸ ✸ ✸

Nuclear Regulatory Commission ✸ ✸ ✸ ✸

Small Business Administration ✸ ✸ ✸ ✸

Tennessee Valley Authority ✔ ✔

United States Postal Service ✔ ✔ ✔ ■

✸ agencies notified the ACHP and stated that the provisions set forth in Section 3 of EO 13287 did not apply to them, 

because they did not own real property.

◆ agencies notified the ACHP that they will no longer be submitting individual Section 3 of EO 13287 progress reports 

from their parent agency.

● departments allow individual bureaus and agencies within the department to submit individual Section 3 of EO 13287 

progress reports.

▲ previously had not submitted under Section 3 of EO 13287.

■ agency submitted draft or final progress report at time of production of the Report to the President.

AGENCY 2004 baseline 

report filed

2005 progress 

report filed

2008 progress 

report filed

2011 progress 

report filed

APPENDIX D—EXECUTIVE BRANCH AGENCIES’ COMPLIANCE WITH EO 13287 | 87
APPENDIX E: FEDERAL 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 AMP that 

addresses, at a minimum, the FRPC 

Guiding Principles and the AMP required 

components.

OMB Agencies listed in 

901(b)(1) and (b)(2) 

title 31; DHS

Annually, 

dependent 

upon the 

quarter 

OMB 

approved 

previous 

AMP

SFFAS 29 

(Heritage 

Assets)

Disclosure requirements applicable to 

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 

CFO Act, GMRA, and 

the ATDA

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

Triennial, 

beginning 

September 

2005

EO 13514: 

Strategic 

Sustainability 

Performance 

Plan and 

Annual 

Updates

Prepare a SSPP 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

June 2010 

and annually 

thereafter

88 | APPENDIX E—FEDERAL REAL PROPERTY REPORTING

ADVISORY COUNCIL ON HISTORIC PRESERVATION

1100 PENNSYLVANIA AVENUE NW, SUITE 803

WASHINGTON, DC 20004

PHONE: 202-606-8503 • FAX: 202-606-8647

WWW.ACHP.GOV

Preserving America’s Heritage