STEWARDSHIP

IN A SPIRIT of

A REPORT ON FEDERAL HISTORIC 

PROPERTY MANAGEMENT

2018
1 ACHP CHAIRMAN’S MESSAGE

2 EXECUTIVE SUMMARY

5 CHAPTER 1: BACKGROUND AND INTRODUCTION

11 CHAPTER 2: IDENTIFYING HISTORIC PROPERTIES

25 CHAPTER 3: PROTECTING HISTORIC PROPERTIES

41 CHAPTER 4: USING HISTORIC PROPERTIES

55 CHAPTER 5:

61 APPENDICES

PRELIMINARY PATTERNS AND TRENDS IN ANALYSIS 

OF FEDERAL REAL PROPERTY PROFILE DATA

LIST OF AGENCIES REPORTING

LINKS TO AGENCY SUBMISSIONS AND ACKNOWLEDGEMENTS

TABLE OF

CONTENTS

Front Cover Photos

Top: NHL nuclear cargo ship N.S. Savannah, U.S. Department of Transportation, Maritime Administration, Canton Marine 

Terminal, Baltimore, MD (photo courtesy Gene Carl Feldman). Center L-R: Launchpad 39A with SpaceX Falcon rocket, 

Kennedy Space Center, FL (photo courtesy NASA). Old Post Office and Custom House, Key West, FL ( Jjiawangkun Fotolia). 

Aerial view of Governors Island and Manhattan, NY (Richard Cavalleri Shutterstock). Naval Medical Center San Diego, CA 

(f8grapher Fotolia). Bottom: Dayton VA Medical Center Grotto and Gardens restoration, Dayton, OH (photo courtesy 

American Veterans Heritage Center)

This page: Apollo Mission Operations Control Room 1969, Houston, TX (photo courtesy NASA)
February 15, 2018

The Advisory Council on Historic Preservation (ACHP) is pleased to present the fifth 

triennial report on how well federal agencies manage their historic properties, pursuant to 

Executive Order 13287 “Preserve America.” Federal agencies were required to submit progress 

reports to the ACHP and the Secretary of the Interior in 2017 on the status of their efforts 

to identify, protect, and use their historic properties. As agencies continue to work smarter to 

provide critical infrastructure and reduce the federal footprint to control costs, they have also 

found opportunities to optimize the use of historic properties to meet mission requirements, 

increase energy efficiency and resiliency, assist in the delivery of infrastructure, and promote 

economic development and job creation in local communities.

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

and productive use of historic properties owned by the federal government. Based on the 

federal agency progress reports and our daily business working with federal agencies all over 

the country, the ACHP has identified several preservation challenges and accompanying 

recommendations to advance the goals of the Executive Order and the National Historic 

Preservation Act.

The ACHP supports the broad goals of cost efficient, effective, sustainable, and resilient 

federal property management. We are also committed to building a more inclusive historic 

preservation program, and ensuring that all communities in our diverse nation have a stake in 

preserving historic properties of importance and significance to them. We encourage federal 

leadership and interest in the stewardship of historic properties in federal ownership and 

appreciate the attention given to this important report. 

Milford Wayne Donaldson, FAIA

Chairman

Advisory Council on Historic Preservation

CHAIRMAN DONALDSON’S 

MESSAGE

An independent federal agency, the 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. The ACHP promotes historic preservation to foster the understanding of the nation’s heritage and 

the contribution that historic preservation can make to contemporary communities and their economic and 

social well-being.

 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 1
This report to the President is required every three years under Executive Order (EO) 

No. 13287, “Preserve America.” The report focuses on the state of the federal government’s 

efforts to identify, protect, and utilize their historic properties and their contribution to 

local economic development between 2014 and 2017. EO 13287 reinforces the role of federal 

agencies as stewards of their historic properties and underscores the importance of federal 

agency efforts to inventory, protect, and use these properties. Federal historic properties play 

a diverse range of roles, from providing infrastructure critical for agency missions, to housing 

members of the military and federal offices, as sacred places important to Native Americans 

and Native Hawai’ians, to sharing stories of American history with visitors.

Information in this report is derived primarily from the 23 federal agency progress reports 

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

the Interior. Agency reports focused on progress made in identifying, protecting, and using 

historic properties in federal ownership since the last report in 2015. Federal agencies continue 

to provide creative examples of historic properties adaptively reused and rehabilitated to 

be energy efficient and resilient, as well as historic properties leased or disposed to parties 

responsible for their preservation. Collectively, these reports also demonstrated that there 

remains wide-spread support among the public for the protection and use of historic 

properties, and that federal efforts to do so strengthen communities and contribute to a 

stronger economy through the creation of jobs. 

In addition to the review of the agency progress reports, the findings and recommendations 

presented in Chapter 5 of this report also are informed by the ACHP’s extensive, and 

EXECUTIVE

SUMMARY

Traces of the famous Oregon 

Trail carved in the land heading 

west, Wyoming (iStockphoto)

2 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018
nationwide, interaction with federal agencies and preservation partners on various 

undertakings, programs, and initiatives over the last three years. The preservation findings and 

conclusions identified over the current reporting cycle include the following:

FINDING: Agencies that have already used Section 106 program alternatives were able 

to improve the efficiency and cost effectiveness of project reviews. 

FINDING: Efforts to identify historic properties and ensure that consistent information 

about historic property inventory efforts are made available electronically 

can better inform and improve real property management and federal and 

non-federal planning. 

FINDING: Partnerships can leverage limited federal resources and provide important 

benefits to federal agencies in the identification, protection, and use of 

historic properties. 

FINDING: Agencies would benefit from more effective mechanisms to ensure timely 

involvement of Indian tribes and Native Hawai’ian organizations in 

property management activities and infrastructure planning. 

FINDING: Further development of policies and procedures to assist federal agencies in 

considering historic properties as part of their efforts to comply with “Reduce 

the Footprint” requirements would improve preservation outcomes without 

delaying compliance with these requirements.

FINDING: Fostering and encouraging the reuse of historic facilities by federal agencies 

or others creates cost-effective preservation outcomes. 

Recommendations to address these findings are presented in Chapter 5.

The ACHP is committed to assisting federal agencies in implementing these recommendations 

so that future actions proposed by the Administration, departments, and agencies recognize 

historic properties as important public assets and are given appropriate consideration 

when planning for federal real property management strategies and initiatives that address 

infrastructure renewal, energy efficiency, resiliency, and long-term preservation.

Acting YAP SHPO Francis Reg 

explains the restoration of a 

men’s house on Yap, a project 

partially sponsored by NPS.

 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 3
The “Four Corners of Law” Charleston, SC, Meeting and 

Broad streets, including U.S. Post Office and Courthouse 

(photo courtesy Lauren Northup)
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 5

This is the fifth triennial report on the status of federal property-owning agencies’ progress in 

identifying, protecting, and using their historic properties. These progress reports are required 

under Section 3 of EO 13287, “Preserve America,” signed by President George W. Bush 

in 2003. The ACHP and the Secretary of the Interior review and analyze the information 

submitted and present their findings to the President by February 15, 2018. 

The ACHP is an independent federal agency that promotes the preservation, enhancement, 

and sustainable use of the nation’s diverse historic resources and advises the President and 

Congress on national historic preservation policy. The ACHP also oversees implementation 

of Section 3 of the EO. The full text of the “Preserve America” EO can be found here: http://

www.preserveamerica.gov/Executive%20Order%2013287.pdf. The membership of the ACHP 

can be found here: http://www.achp.gov/members.html.

The federal government is the steward of thousands of historic properties of all kinds 

across the country and in all its territories—these include buildings, structures, traditional 

landscapes of religious and cultural significance to Indian tribes and Native Hawai’ian 

organizations (NHOs), archaeological sites and districts, scientific and highly technical 

properties and objects, and others. This EO focuses on reinforcing the preservation 

stewardship responsibilities of federal agencies, which began with the Antiquities Act of 

1906, was expanded in the Historic Sites Act of 1935, was reinforced in 1966 in the National 

Historic Preservation Act (NHPA), specifically in Sections 1, 2, and 110, and by subsequent 

amendments to the NHPA. 

BACKGROUND AND 

INTRODUCTION

CHAPTER 1

Fort Hancock Homes, Gateway 

National Recreation Area, New 

Jersey (Andrew Kazmierski 

Fotolia)
6 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

The goal of these statutes and this EO is to ensure that federal agencies are good stewards of 

historic properties for the benefit of the American people, while still meeting mission needs. 

Section 110 of the NHPA (54 USC 3061) sets forth the broad affirmative federal agency 

responsibilities with respect to their programs for balancing mission needs with historic 

values. The intent of Section 110 is to ensure historic preservation is fully integrated into 

the programs of federal agencies. To assist agencies in achieving the purposes of Section 110, 

the ACHP and the National Park Service (NPS) have jointly issued guidance entitled The 

Section 110 Guidelines: Annotated Guidelines for Federal Agency Responsibilities under Section 110 of the 

National Historic Preservation Act (available here: https://www.nps.gov/fpi/Section110.html). 

Many agencies meet these responsibilities through compliance with Section 106 of the NHPA 

(54 USC 306108) for their undertakings. Section 106 of the NHPA requires federal agencies 

to “take into account” the effects of their projects and programs on historic properties and 

provide the ACHP a “reasonable opportunity” to comment on them. The ACHP’s regulations 

implementing Section 106 (36 CFR Part 800, http://www.achp.gov/regs-rev04.pdf ) set forth 

this review process, whereby the federal agency consults with the State Historic Preservation 

Officers (SHPOs), and oftentimes with Indian tribes or NHOs, to determine if the proposed 

project will have an effect on a property listed on or eligible for listing on the National Register 

of Historic Places (NRHP), and if so, what measures might be appropriate to avoid, minimize, 

or mitigate adverse effects.

Agency Section 3 reports are intended to analyze their progress in meeting the goals of 

the EO since the last report three years ago. A universal sentiment running through all the 

submitted reports is that federal agencies are proud of their stewardship of historic properties; 

they want to tell their story and how they contribute to economic development and resource 

independence. The many examples federal agencies provided in their reports run the gamut 

of historic property type, threats to them, and preservation opportunities grasped. How these 

agencies responded with their own historic preservation initiatives, partnerships, and creative 

solutions to better protect these resources, while providing the American public more and 

better chances to enjoy and appreciate them, deserves to be told in their own words.

While this report addresses the requirements of Section 3 of the EO, other sections of the 

EO also spell out federal agency oversight responsibilities. Section 1 reaffirms the historic 

preservation principles set out in Sections 1 and 2 of the NHPA—that federal agencies should 

exhibit leadership in the field of historic preservation and should use their historic properties 

where practicable. Section 2 of the EO calls for federal agencies to build preservation 

partnerships where possible and “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.” Section 3 (among other things) requires federal agencies 

“with real property management responsibilities” to assess the status and state of their historic 

preservation stewardship, first in an initial report to the ACHP and the Secretary of the 

Interior by September 30, 2004, and then every three years afterwards.

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

and use of historic properties as federal assets and, where practicable, contribute to local 

communities and their economies. Section 5 states that federal agencies are to use their 

historic properties in concert with state, tribal, and local tourism programs to foster heritage 

tourism opportunities. How federal agencies carry out their duties under Sections 2, 4, and 5 

of the Preserve America EO are touched on and discussed to some extent in this report.
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 7

Throughout this report the term “historic properties” is used as defined in the NHPA as those 

buildings, structures, objects, sites, and districts that are listed in, or are eligible for listing in, 

the NRHP. The term includes National Historic Landmarks (NHLs) which are designated 

as such by the Secretary of the Interior because they possess exceptional value or quality in 

illustrating or interpreting the heritage of the nation. 

PREVIOUS SECTION 3 REPORTING

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

reports to the ACHP and the Secretary of the Interior as required by the Preserve America 

EO. The chart in Appendix 2 illustrates the history of agency Section 3 reporting.

Agencies were encouraged to utilize existing reporting systems to prepare this report. The 

ACHP posts the progress reports received from agencies on the web at http://www.achp.

gov/section3/. Agencies may elect not to submit progress reports for a variety of reasons, 

including because the provisions in EO 13287 do not apply to them as they do not own real 

property. Further, individual bureaus may elect to submit separate progress reports one cycle 

but consolidated reports with their parent agency or department in another reporting cycle. 

While the ACHP provided its Advisory Guidelines Implementing Section 3: Reporting Progress on 

the Identification, Protection, and Use of Federal Historic Properties (http://www.achp.gov/docs/

advisory-guidelines-2017.pdf ), some agencies used the questions in the advisory guidelines, 

while others did not. As a result of these variables, it is difficult to present a comprehensive 

picture of federal agency stewardship across the board. However, trends can be discerned in the 

information provided, and these are presented in Chapter 5, “Findings and Recommendations.” 

 

15

2005 2008

PROGRESS REPORTS SUBMITTED

2005-2017

2011 2014 2017

20

25

23

21

24

20

23
8 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

PRESERVATION INITIATIVES 2014-2017

The current reporting period spans two Administrations, and in the first year of the current 

Administration several laws, EOs, and policies have been and are being promulgated that 

are already having an impact on how the federal government utilizes its historic properties 

and how it will carry out its stewardship responsibilities. The extent to which real property 

management practices and others (budget, shrinking government, etc.) have changed or stayed 

the same are discussed throughout this document.

›› Permitting, streamlining, and infrastructure. During the reporting period, the federal 

government focused legislative and policy attention on the improvement of the federal 

permitting process for infrastructure projects affecting historic properties on federal lands. 

The Fixing America’s Surface Transportation Act (FAST) Act was passed in December 

2015. Title 41 of the FAST Act created the Federal Permitting Improvement Steering 

Council (Permitting Council), of which the ACHP is a member. The Permitting Council 

plays a key role in implementing specific provisions in Title 41 of the FAST Act. The 

FAST-41 process was designed to improve the timeliness, predictability, and transparency 

of the federal environmental review and authorization process for certain large-scale 

infrastructure projects, some of which may be located in part on federal land. FAST41 provides for improving the federal coordination of environmental reviews, including 

Section 106 reviews, but does not alter an agency’s responsibility to comply with Section 

106 or change the requirements or timeframes in the ACHP’s regulations or an existing 

Section 106 Programmatic Agreement. 

Federal agencies develop permitting timetables for projects following the FAST-41 

process. Milestones for environmental review and other information about covered 

projects are publicly tracked on the Federal Permitting Dashboard. FAST-41 also requires 

the Permitting Council to develop best practices that can be applied broadly to federal 

environmental reviews and authorizations to all infrastructure projects.

On August 15, 2017, the President issued EO 13807, “Establishing Discipline and 

Accountability in the Environmental Review and Permitting Process for Infrastructure,” 

with the goal of increasing the coordination, predictability, and transparency of the 

federal environmental review and permitting process for infrastructure projects. This EO 

strengthens the accountability of federal agencies in carrying out environmental review for 

major infrastructure projects and includes important new milestones–namely, for agencies 

to coordinate their reviews and complete them within an average of two years. 

The ACHP participated in an interagency consultation process led by the Departments 

of the Army, Interior, and Justice in late 2016 to identify opportunities for more effectively 

consulting Indian tribes on infrastructure projects affecting historic properties on 

federal lands and prepared a report with recommendations specific to the Section 106 

process in response to comments offered by Indian tribes [http://www.achp.gov/docs/

achp-infrastructure-report.pdf ]. The ACHP’s report is a companion publication to 

an interagency report on Improving Tribal Consultation and Tribal Involvement in Federal 

Infrastructure Decisions released in January 2017 in response to the listening sessions. 

[https://www.bia.gov/sites/bia.gov/files/assets/as-ia/pdf/idc2-060030.pdf ]

These developments are part of an ongoing emphasis within the federal government on 

improving efficiency and increasing interagency coordination for infrastructure project 

reviews. Federal land-managing agencies have been actively involved in these efforts 

as they consider the siting of pipelines, electric transmission lines, oil and gas drilling, 

communication facilities, and other types of infrastructure on their property.
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 9

›› Building a More Inclusive Preservation Program. The ACHP has undertaken an 

initiative to engage diverse audiences in conversations about historic preservation to 

ensure the national preservation program recognizes the heritage of all Americans and 

provides access to tools and activities for all who care about that heritage. In a series 

of conferences, listening sessions, and meetings with diverse constituencies, including 

listening sessions in Boston, San Francisco, Santa Fe, and Tampa to hear directly from 

Asian American and Pacific Islander, Latino, and African American communities, a 

consistent set of themes rose to the surface during these conversations. Those include the 

following:

• Preserve cultural values, including the intangible aspects of historic places;

• Recognize all Americans’ history and protect the special cultural identity of places, 

communities, and landscapes;

• Make heritage relevant for youth;

• Develop community and organizational capacity, including partnerships;

• Integrate cultural values and be aware of community needs when implementing 

standard historic preservation processes and projects;

• Weave culture and public engagement more sensitively into planning and resource 

management by increasing consultation efforts and opportunities.

At the summer 2016 business meeting, ACHP members voted unanimously to adopt final 

recommendations that will institutionalize the goals of a multi-year initiative to build a 

more inclusive national preservation program. The concepts and ideas which developed 

into these recommendations began to surface years ago through the work of historic 

preservation organizations such as the ACHP, NPS, and the National Trust for Historic 

Preservation, as well as programs such as Preserve America.

›› The National Historic Preservation Program at 50: Priorities and 

Recommendations for the Future. As part of its commemoration of the 50th 

anniversary of the NHPA in 2016, in consultation with its members (including federal 

agencies) and with input from a variety of other public and private parties, the ACHP 

developed a report and recommendations to assess and improve the National Historic 

Preservation Program. Included for consideration were some of the key tools currently 

used under the NHPA and related authorities, such as the Historic Preservation Fund, 

the NRHP, Section 106 review, and the Federal Historic Preservation Tax Credits.

The final report, The National Historic Preservation Program at 50: Priorities and 

Recommendations for the Future, was approved by the ACHP on December 1, 2016, and 

released to the public in both print and online versions in March 2017 (http://www.achp.

gov/docs/Preservation50FinalReport.pdf ). A number of the recommendations overlap 

with or complement actions and initiatives already being undertaken by the ACHP and 

other parties, including the Building a More Inclusive Preservation Program noted above:

• Maintaining and strengthening public support for preservation;

• Enhancing leadership at the policy and program levels of the federal government;

• Improving preservation planning, including better integration of preservation concerns 

with other environmental and planning review processes;

• Strengthening sustainable funding and investment in preservation, both public and 

private;
10 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

• Expanding and encouraging public engagement in deciding what is important and how 

significant resources should be managed;

• Advancing equity and inclusion in what is preserved;

• Responding to indigenous peoples’ concerns about the preservation of their heritage;

• Enhancing further appreciation for heritage through formal and informal education; 

• Promoting more effective collaboration and partnerships that advance preservation 

goals; and

• Addressing the preservation consequences of climate change, disaster planning and 

recovery, and environmental sustainability.

While the report is intended to offer a blueprint for the future, many of these 

recommendations are already being adopted and implemented by the federal agencies 

discussed in this Section 3 report. Strategies to implement many recommendations are 

presented in Chapter 5 of this report.

INTRODUCTION TO THE 2018 REPORT

A total of 23 departments or agencies reported on their efforts to identify, protect, and use 

their historic properties between the years 2014 to 2017, the current reporting cycle. A list 

of all responding agencies and their history of Section 3 reporting can be found in Appendix 

2. This 2018 report differs from previous Section 3 reports in several ways. First, this report 

was designed from the start to be web-based, with links to other documents and preservation 

resources mentioned in the text. Second, this report focuses specifically on those federal 

agency responsibilities as set out in Section 3 of the EO: to identify, protect, and use historic 

properties. Finally, this report contains more examples and case studies of successful federal 

agency stewardship than previous reports, all to better illustrate the breadth of historic 

properties owned by the federal government, the myriad ways they care for them, and how they 

can contribute to the goals of economic development and resource independence.
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 11

For this report, federal agencies were asked to share with the ACHP and Secretary of the 

Interior information about their efforts to identify historic properties for the period from 2014 

through 2017, including progress since the last report, how their identification methods have 

changed, and how they manage and use their databases. 

OVERVIEW: 

The ACHP believes an accurate, up-to-date inventory of an agency’s historic properties, 

and the steps taken to increase and refine it, is a requisite for determining management 

priorities for those properties. Only with an understanding of their historic properties—the 

historical, economic, and educational values they embody and the agency resources needed and 

realistically available to care for them—can agencies begin to develop management priorities 

for their future.

Federal agency progress on identifying historic properties: 

Between 2014 and 2017 most responding federal agencies continued to make progress in 

identifying historic properties under their ownership. Some smaller agencies reported no 

change in their inventory of historic properties under their ownership, while other small 

agencies carried out surveys that identified new historic properties. As one would expect, the 

nature of the agency (e.g., primarily land-managing agencies or building-managing agencies, 

large agencies or small) influenced the kinds of historic properties identified, and the intensity 

of that identification effort. 

IDENTIFYING HISTORIC 

PROPERTIES 2014-2017

CHAPTER 2

Tennessee Valley Authority and 

tribal archaeologists conducting 

research at Hiawassee Island 

archaeological site, on the 

Tennessee River in east 

Tennessee (photo courtesy TVA)
12 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

Highlights:

›› Department of Homeland Security (DHS) reports that 10 percent of its facilities have 

now been evaluated for historical significance, an increase of 4 percent since the last 

report. 

›› US Postal Service (USPS) reports that 14 percent of all owned properties were evaluated 

for NRHP eligibility over the past three years, and now counts 35 percent of its owned 

properties (3,070 out of a total of 8,761) as historic.

›› US Geological Survey (USGS) reports completing NRHP eligibility evaluations on 

18 percent of all its properties.

›› Department of Veterans Affairs (VA) listed 20 cemetery properties on the NRHP under 

the Inter-World War National Cemeteries, 1934-1939, Multiple Property Submission.

›› Tennessee Valley Authority (TVA) surveyed 4,075 acres of its land during this period, 

and now has evaluated the NRHP eligibility of 11,500 archaeological sites and 380 

buildings and structures on its 293,000 acres of non-inundated land.

›› Bureau of Land Management (BLM) surveyed 1,539,992 of its 245 million acres of public 

lands, reports that it recorded 23,256 sites, with 7,557 determined eligible for the NRHP, 

and found 10,953 to be not eligible. Through FY 2016, BLM cumulatively has surveyed 

more than 25 million acres (approximately 10 percent of BLM surface lands) for historic 

properties, with an average of 513,000 acres surveyed annually from FY 2014 through 

FY 2016.

›› In the 2014 Preserve America progress report, the NPS was responsible for the 

stewardship of 401 park units containing more than 84 million acres within their 

boundaries. Today, the national park system includes 417 units in all 50 states, the District 

of Columbia, and surrounding territories.

›› Department of Defense (DoD) surveyed approximately 184,000 acres for archaeological 

resources, increasing the total land surveyed to more than 9 million acres. DoD also 

evaluated more than 7,000 buildings and structures for NRHP eligibility. 

›› The US Army Corps of Engineers (USACE) reports at least 396 newly recorded historic 

properties by 12 USACE District offices. 

›› Under a multiyear compliance initiative nearing completion, the General Services 

Administration (GSA) has evaluated all but a few of its buildings that are more than 

50 years old. During the 2015-2017 reporting period, GSA evaluated 62 properties 

and nominated 39 eligible properties to the NRHP. Eighty-one percent of their eligible 

historic properties have been listed in the NRHP. GSA’s national leadership role in 

listing its historic properties has been lauded by the Department of the Interior (DOI). 

Evaluation of the remaining few properties included in this initiative is underway, while 

newly evaluated historic properties will continue along the path to listing. 
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 13

Federal agency policies and procedures to identify historic properties:

Federal agencies have a variety of policies and procedures to identify their historic properties. 

These are derived from statutes both specific (e.g., Sections 1, 106, and 110 of the NHPA; 

Archeological Resources Protection Act) and general (Federal Lands Policy Management Act, 

National Environmental Policy Act [NEPA], etc.), from Executive Orders (e.g., President 

Bush’s EO 13327, Federal Real Property Asset Management, 2004) to internal department and 

agency policy and requirements that implement these statutes and EOs.

Most land-managing agencies who reported this cycle describe their internal agency 

management guidance as their “prime directive.” In some cases, this guidance is based on a 

Programmatic Agreement that is often national in scope—the BLM and NPS Nationwide 

Agreements, for example. Agency practices provide a framework for carrying out historic 

property identification and stewardship in the context of multi-use missions—often 

encompassing recreation, resource sustainability, economic development, and energy 

development. Procedures for reviewing project plans for their possible effects on historic 

properties are laid out within these policies and procedures (as well as procedures for 

compliance with other preservation laws, like the Archaeological Resources Protection Act 

[ARPA] and the Native American Graves Protection and Repatriation Act [NAGPRA]). 

Federal agencies that primarily manage buildings and structures also have internal preservation 

directives. DHS’s Directive 017-01, Historic Preservation in Asset Management and Operations 

and Accompanying Instruction Guide to the Historic Preservation in Asset Management Operations,

applies to all its component agencies, while these agencies: FEMA, US Customs and Border 

Protection (CBP), US Coast Guard (USCG) also have their individual policies tailored to 

their specific missions and historic resources. It should also be noted that the Federal Bureau 

of Prisons (BOP) recently issued historic guidelines in its Facilities Operational manual in 

July 2017. DoD does not have any specific preservation directives; the only cultural resources 

directive is general DoD instruction 4715.16 “Cultural Resources Management” (issued 2008).

In 2015, TVA evaluated the NRHP eligibility of TVA’s hydroelectric system. TVA’s dams and 

associated structures were found to be historically significant at the national, state, and local 

levels due to their association with broad patterns of history and engineering and architectural 

importance. The Keeper of the NRHP accepted TVA’s Multiple Property Documentation Form, 

along with the individual nominations of its Norris, Wheeler, and Guntersville Hydroelectric 

facilities. Twenty-two additional facilities were listed in the NRHP in 2017, so that today, all of the 

major hydro facilities that TVA constructed are now recognized by the NRHP.

NPS archaeologists care for more than 80,000 archaeological sites that have been identified in 

national parks. At the end of FY 2017, 80,911 known archaeological sites were located within 

national parks. Inventory and evaluation of sites is ongoing.
14 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

The National Soldiers Home “Old Main” at 

the Clement J. Zablocki VA Medical Center, 

Milwaukee, WI (photo courtesy James 

Steakley/Wikimedia Commons)
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 15

The Department of the Air Force implemented standardized and electronic Integrated Cultural Resources Management Plan 

(ICRMP) templates in 2015 and requires all existing and newly developed ICRMPs to utilize the template. This standardization 

of ICRMPs allows quick review by base, installation support teams, and the Air Force Civil Engineer Center which (1) reduces 

data call time and energy, (2) allows in-house updates, (3) allows intra-service sharing of lessons learned; and (4) creates a more 

uniform set of standard operating procedures.

The “Section 110” requirement for survey of historic properties on federal property is in the NHPA: Each Federal agency 

shall establish a preservation program. The program shall ensure that historic property under the jurisdiction or control of the agency is 

identified, evaluated, and nominated to the NRHP. 54 U.S.C. § 306102(a) - (b)(1).

USACE Mobile District developed a new tool “RECENTPAST” to assist with management and protection of sites on USACE 

project lands. This tool consists of digital maps showing culturally sensitive areas overlaid with areas where the District is 

planning water and land management activities.

In carrying out their agencies’ often multiple missions—energy development and distribution, 

national defense, economic development, and recreation, to name a few—responders say 

when implemented as intended, their internal historic preservation policies and the attendant 

procedures to implement them are effective in ensuring project reviews are completed in a 

timely manner avoiding delays, and ensuring historic preservation is substantively considered.

However, one sticking point is that, based on ACHP experience and Section 3 reporting, some 

federal agencies’ policies and procedures for identification are only starting to keep up with 

current property conceptions and thinking in historic preservation, especially in terms of early 

consultation with Indian tribes and NHOs, identifying and addressing effects to traditional 

cultural places (TCPs) and cultural landscapes, and in consideration of modernist buildings as 

potentially significant and worthy of consideration. The larger agencies like BLM, TVA, and 

GSA are on the forefront of these changing mores and practices.

Budgeting for historic property identification:

While some agencies (e.g., GSA, National Aeronautics and Space Administration [NASA], 

TVA) reported that they budget expressly for Section 110 surveys, the ACHP continues to 

see the vast majority of federal historic property identification occurring within the context of 

the Section 106 process. This is reactive and not proactive, and can lead to unnecessary delays 

in project review and in allocating scarce resources for property stewardship. While many 

federal agencies recognize this, and are trying to refocus efforts to support Section 110 surveys 
16 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

in part to keep ahead of plans for the reduction of the federal real property inventory and 

reinvestment in existing infrastructure, in every reporting cycle since 2004 a lack of available 

resources is the primary challenge to increasing capacity to identify the historic properties they 

own. The number of agencies citing this as the reason for doing inventory has not improved 

over the past three years.

TVA has a general policy to survey 1,000 acres each year for historic properties. Other 

agencies allocating for Section 110 inventories gave several reasons for doing so. GSA said,

To remain a step ahead of plans for reinvesting in buildings potentially eligible 

for the NRHP, GSA’s regional preservation programs budget for Section 110 

determinations of eligibility and building preservation plans as part of each 

region’s yearly due diligence.

NASA reports that while it has made, “a general shift from reactive, Section 106-driven 

identification to proactive, comprehensive Section 110 identification of historic properties” and 

now has “comprehensive, gate-to-gate surveys of resources over 45 years of age” at several of its 

Centers, it also remarked that

... the current climate of federal budgetary restrictions and the move toward 

commercialization of space exploration means that NASA has less discretionary 

funding to redirect from mission-critical programs. This can result in the deferral 

of Section 110 identification and reliance on Section 106 identification, since the 

latter is required to carry out the physical improvements necessary to advance a 

project, which is directly attributable to the mission.

As an example, the BOP reports that due to funding restrictions, no identification studies 

under Section 106 have taken place in the last three years, and it has no funding to address 

its facilities that are 50 years of age or older. Even agencies with substantial federal historic 

preservation programs have seen, at best, a flat Cultural Resource Management (CRM) 

funding and a consequent reduction in (or inability to fill) dedicated full-time employees 

(FTEs) in recent years. BLM reported that it has approximately 18 CRM vacancies, critical 

to an agency that manages so much land. While not providing dollar figures, the Fish and 

Wildlife Service (FWS) noted it was able to bring on three additional CRM positions in 

FY 2016, but also cautioned that it needed an additional 16 FTEs to meet current 

requirements. A lack of staff was the major reason FWS cited for the 169 Section 106 

undertakings that were not completed in FY 2016, with the proposed activities put on hold.

BLM reports Section 110 activities occur when funding is available and staff can devote their time 

to those investigations, and is typically focused on high use/high impact areas. 

Operations of the National Park Service (CR-ONPS) funding source supports research, 

documentation, stabilization, and conservation of NPS cultural resources, and directly supports the 

goals of resource stewardship, relevance, and education. These funds support park planning needs 

relating to proposed development and allow parks to inventory and evaluate cultural resources 

per the requirements of Section 110 of the NHPA. They also provide for baseline research and 

treatment guidance that is critical to support the streamlined compliance process for deferred 

maintenance and infrastructure projects that impact park resources. 
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 17

Historic property information management—the FRPP and 

other systems: 

Over the past three years federal agencies have improved their individual databases and 

reporting standards to better account for their historic properties. This has been achieved in 

conjunction with the efforts of the Federal Real Property Profile (FRPP) that was created in 

part to assist agencies in better identifying and managing their real property holdings. 

The FRPP is managed by the Federal Real Property Council (FRPC), and houses information 

about the nature, use, and extent of the federal government’s real property assets. It contains 

data on all executive branch agency real property assets within and outside the United States, 

including improvements on federal land, except when otherwise required for reasons of 

national security, in accordance with EO 13327 (Federal Real Property Management, 2004). 

A preliminary analysis of patterns and trends in FRPP data on historic properties is presented 

in Appendix 1.

Some agencies also continue to use separate asset management systems because their needs go 

beyond what the FRPP is designed primarily to document: above-ground real property, so that 

information on archaeological sites, TCPs, and historic districts is either lacking or incomplete. 

The Government Accountability Office’s (GAO) report (Federal Real Property: Improved Data 

Needed to Strategically Manage Historic Buildings, 2012) recommended that GSA collaborate 

with FRPC member agencies and others to address the need for improved data on historic 

buildings in the FRPP. In 2013, the ACHP created a work group to address these concerns. 

Comprising representatives of GSA, DoD, DHS, VA, DOI (including NPS and BLM), the 

National Conference of State Historic Preservation Officers (NCSHPO), and the National 

Trust for Historic Preservation, the work group developed and approved recommendations 

to improve the “historical status” field of the FRPP, which were submitted to GSA’s Office of 

Government-wide Policy and incorporated in the 2014 edition (and subsequent editions) of 

the Data Dictionary.

For the most part, though, and aside from formal listing on the NRHP, historic properties 

information continues to be included in inventories maintained by individual federal agencies, 

and also by state, tribal, and local governments. This causes problems for a comprehensive, 

searchable, and accessible inventory of the nation’s historic properties which could provide 

a strong planning tool, especially in the case of disasters, emergencies, and expanding and 

updating infrastructure. 

Linking existing lists of historic properties and expanding them into a comprehensive 

inventory would require encouraging and supporting use of standards addressing common 

data formats and management tools, including digitization and GIS interface across federal 

agency, state, and tribal lines. For the past 10 years, the ACHP has continued to explore 

the development of such a comprehensive digital inventory of federal historic properties for 

federal, state, tribal agencies, and industry to assist in meeting the requirements of Sections 

106 and 110. The ability to characterize historic properties within a particular area could 

greatly speed up the siting of new infrastructure and resource extraction that affect historic 

properties on federal lands. Such an inventory was one recommendation made in the 2007 

Preserve America report and in the ACHP’s The National Historic Preservation Program at 50: 

Priorities and Recommendations for the Future. Such an inventory would include the “information 

necessary for management, planning, and decision making ... government agencies, Indian 

tribes, businesses, and citizens need usable information as the basis for decisions on protection, 

funding, revitalizing, and interpreting historic properties.”
18 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

The importance of partnerships to identify historic properties:

While many federal agencies reported on their use of partnerships for resource protection 

and use, some also entered into agreements for inventory and survey purposes. The common 

thread in agency responses is the relationship between the federal agency and the SHPOs and, 

especially for land managing agencies, with Tribal Historic Preservation Officers (THPOs) 

and federally recognized Indian tribes. Most agencies reporting also noted that they partnered 

with other federal agencies as the need arises, usually because they also owned or managed 

adjacent resources or had specific kinds of expertise.

Highlights:

›› Bureau of Reclamation’s (Reclamation) Grand Coulee Power Office partnered with the 

Bonneville Power Administration, NPS’s Lake Roosevelt National Recreation Area, 

USACE, the Washington and Montana SHPOs, the Confederated Salish and Kootenai 

Tribes, the Spokane Tribe of Indians, and the Confederated Tribes of the Colville 

Reservation to survey 36,977 acres of federal lands for the Federal Columbia River Power 

System Cultural Resources Management program.

›› US International Boundary and Water Commission (USIBWC) manages site forms and 

reports on several state databases (e.g., the South Coastal Information Center at San 

Diego State University, databases for the Arizona and New Mexico SHPOs, and the 

Texas Archeological Research Laboratory in Austin).

›› DHS notes that a 2017 SHPO survey found that FEMA was ranked No. 2 of all federal 

agencies in maintaining good working relationships with them.

Given that the FRPP is currently not equipped to manage information on archaeological properties, 

the data collected for the NPS’ Federal Archeology Program’s Secretary’s Report to Congress would 

seem to have real potential as a tool to track and assess federal archaeology activities. This report 

is the only one that specifically collected data on the full range of federal agencies’ archaeological 

stewardship activities—site identification, protection, excavation, reporting, and curation—in a 

comparable format.

Properties located but not evaluated: 

The ACHP continues to see the trend of cultural resources being located and identified but 

not evaluated to determine their NRHP significance. This approach often has unforeseen 

consequences for efficient property management. A major consequence is that these 

unevaluated properties become what has been termed “persistent resources” that stay on the 

agency’s books as a form of constant background noise, creating management inefficiencies 

until decisions are finally made about their significance. Agencies may unnecessarily spend 

time and scarce money to avoid such properties in their management of them or in future 

Section 106 reviews.
Montana BLM continues its partnership with Chief Dull Knife College and 

the Northern Cheyenne Tribe on an Ecoregional Ethnographic Assessment, 

which focuses on identifying, documenting, evaluating, and mapping places 

of traditional religious or cultural significance to the tribe, and identifying 

culturally important plant and animal species and their associated ecosystems 

that are critical for the maintenance of Northern Cheyenne cultures and 

traditions. The tribe benefits by capturing this legacy data for present and 

future generations. BLM benefits by gaining a better understanding of the 

tribe’s significant resources and by being able to make more informed land 

management decisions. BLM plans to begin work with the Crow and Yankton 

Sioux Tribes on similar projects.

Oral history interviews conducted with members of the 

Northern Cheyenne Tribe (Photographs courtesy of Chief 

Dull Knife College, provided by BLM)

BUREAU OF LAND 

MANAGEMENT ETHNOGRAPHIC 

ASSESSMENT PARTNERSHIP

CASE

STUDY

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20 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

In 2015, TVA partnered with three tribes—Muskogee Creek Nation of Oklahoma, Chickasaw 

Nation, and United Keetoowah Band of Cherokee Indians—to conduct non-invasive geophysical 

field training and archaeological feature identification at Hiwassee Island in the Tennessee 

River. The 2015 results were successful enough that TVA initiated another partnership project 

with the tribes in FY17 to conduct limited ground testing of the features identified earlier. TVA 

also provided training opportunities for non-archaeologist tribal representatives as part of the 

excavations.

Investigating the USS Monitor wreck, Monitor National Marine Sanctuary, Atlantic Ocean (photo courtesy NOAA)
Three courthouses were designated by the Secretary of 

the Interior as NHLs within the context of the Theme 

Study on Civil Rights in America: Racial Voting Rights. These 

previously NRHP-listed courthouses were designated as 

NHLs in thematic nominations associated with the Civil 

Rights Movement and desegregation in public education: the 

Frank M. Johnson Jr. Federal Building and U.S. Courthouse 

(originally the United States Post Office and Courthouse) 

in Montgomery, Alabama; the Elbert P. Tuttle U.S. Court 

of Appeals Building (originally the U.S. Post Office and 

Courthouse), in Atlanta, Georgia; and the John Minor Wisdom 

U.S. Court of Appeals Building (originally the Fifth Circuit U.S. 

Court of Appeals), in New Orleans, Louisiana.

CIVIL RIGHTS NATIONAL 

HISTORIC LANDMARK 

COURTHOUSES

In the 1950s and 1960s, the Fifth Circuit Court of Appeals, 

which had jurisdiction in six southeastern states, shaped the 

Civil Rights Movement with momentous rulings in the wake 

of nation-changing events, including the 1955 Montgomery 

Bus Boycott, 1961 Freedom Rides, the 1965 march from 

Selma to Montgomery, and desegregation of southern schools 

and universities following the Supreme Court’s Brown v. Board 

of Education decisions in 1954 and 1955. These rulings served 

as the basis for pioneering legislative and judicial reform that 

followed. The three NHL-designated courthouses, as well 

as GSA’s NRHP-listed former Montgomery Greyhound Bus 

Station (acquired as part of the courthouse site), are also 

among several properties—including GSA’s Lewis F. Powell Jr. 

U.S. Courthouse in Richmond, Virginia, under consideration 

for inclusion in a World Heritage Site Serial Designation.

The Frank M. Johnson Jr. Federal Building and U.S. Courthouse, Montgomery, AL 

(photo courtesy Carol M. Highsmith Photography, Inc./GSA)

CASE

STUDY

 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 21
BUREAU OF LAND MANAGEMENT 

PERMIAN BASIN PROGRAMMATIC 

AGREEMENT SUCCESS CONTINUES

The Mescalero Plain is a band of wind deposited sand and dunes in southeastern New Mexico, 

with evidence of Paleoindian use since at least 5,000 BC. The plain sits atop the Permian Basin, the 

largest oil and gas basin in North America. The first oil well in the Permian Basin in New Mexico 

was drilled in 1924. By 2003, more than 300,000 acres managed by the BLM field office had been 

surveyed for oil and gas projects, and more than 8,000 archaeological sites had been recorded. 

In New Mexico, most of the oil and gas development in the Permian Basin occurs on 2 million 

acres managed by the BLM Pecos District. The district processes thousands of oil-and-gas 

applications to drill annually, making it one of the busiest offices in the nation. For 30 years, BLM’s 

archaeological program was driven by industry’s needs–in the face of a proposed wellsite, the 

preferred action was “flag and avoid” (survey and record sites, and redesign projects to avoid the 

historic properties). As long as the spacing between developments allowed archaeologists to help 

industry move project footprints to avoid archaeological resources, preservation in place was a 

viable option. However, over time, intense development in some areas made it difficult to locate 

projects without harming archaeological sites. Many sites were being lost due to infrastructure 

maintenance, dune formation, and were ravaged by illegal artifact collecting. An alternative to “flag 

and avoid” was needed.

BLM and the New Mexico SHPO collaborated with archaeologists, tribes, and industry on a 

different approach to balancing energy development and archaeology. The fruits of their efforts 

were embodied in a Section 106 agreement that encompasses 1,700 square miles with the most 

active oil and gas areas. Operating under the agreement is voluntary–if a company chooses the 

agreement procedures, it contributes the cost of the archaeological survey into a mitigation pool. 

Under the terms of the agreement, the partners in the program collaborate to determine how 

the pool’s funds are used, providing effective support for research and interpretation of the area’s 

archaeology.

Since 2008, the oil industry has paid nearly $11 million into the pool. Without the Permian Basin 

agreement, those funds would have been spent on thousands of small surveys. Instead, the funding 

pool has built a comprehensive field program, providing millions of dollars for archaeological 

research and studies that provide a foundation for understanding and managing the area’s 

archaeological resources. Now all resources are managed through a GIS integrated with the New 

Mexico Cultural Resource Information System, replacing outdated records in an easy-to-access 

format. The system provides real-time pictures of surveyed areas and sites, indicating where work 

is needed. The pool supports educational materials and outreach events to engage locals with their 

heritage. Use of the agreement procedures gives industry more predictability and control over 

schedules and budgets needed to operate efficiently and demonstrates that the cultural resources 

projects they fund have real-world benefits. 

The original agreement was so successful that signatories have extended the program’s life through 

a Programmatic Agreement for 10 more years. Innovative use of the Section 106 process shows 

that the years of directed field research have done more to understand and manage the resources 

than 30 years of business as usual.

CASE

STUDY

22 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018
Oil tank and lines; excavating Bloom Mound, Permian Basin; Chaves, Eddy, and Lea Counties, NM (all photos courtesy BLM)

 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 23
U.S. Custom House, New Bedford, 

MA (photo courtesy Carol M. 

Highsmith Photography, Inc./GSA)
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 25

For this report, federal agencies were asked to share with the ACHP and Secretary of the 

Interior information on how they protected historic properties in the period between 2014 and 

2017. They were asked how their programs and procedures have changed or evolved; about 

their staffing levels, access to preservation expertise and continuing education; how they use 

partnerships to protect their historic resources; and whether they make use of Section 106 

program alternatives to meet their stewardship responsibilities.

OVERVIEW: 

Federal agencies protect historic properties in a variety of ways, through personnel education 

and development of in-house expertise, through Section 110 surveys and Section 106 

agreement documents, and via partnerships. The list of diverse partnerships described in this 

report is only a sample of those presented by the responding agencies. The growth in numbers 

and variety over past reporting periods is a very encouraging sign, allowing agencies to leverage 

limited funding for preservation activities for greater impact. In many cases, the manners in 

which agencies are protecting their historic properties have not changed since the last report. 

In other ways, for example in the increased availability of education media and opportunities 

has changed dramatically; agencies have made solid progress in the number of properties 

protected, and the effectiveness in which they do this. The American people expect their 

important federal places to be effectively managed and protected, and the agencies are, more 

often than not, doing the best they can with the resources available to them.

PROTECTING 

HISTORIC PROPERTIES

CHAPTER 3

Ohkay Owingeh Pueblo housing 

preservation project, Rio Arriba 

County, NM (photo courtesy 

HUD)
26 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

Agency programs and procedures to protect historic properties: 

Strides have been made since the last reporting period in 2015 in how agencies protect their 

historic properties. Agencies have been implementing and refining agency guidance and data 

management practices (like BLM, FWS, USGS, BOP, NASA, TVA, USIBWC) and/or 

through internal, cross-departmental preservation or resource-focused working groups (like 

GSA, DHS, National Oceanic and Atmospheric Administration [NOAA], BLM).

As in the past, the most effective and efficient manner in which federal agencies ensure 

protection of their historic properties is through proactive management—a combination 

of continual use and upkeep, condition monitoring, smart resource allocation, informationsharing among stakeholders, and use of staff expertise. Internal agency directives and policy 

set out how they will carry out these duties, with compliance with Section 106 and NEPA for 

the most part serving as the driving forces. Smaller agencies report that the identification and 

assessment of effect provisions in the Section 106 process are their most common protective 

tools, and they tend to rely more on contractors for their preservation activities than do larger 

federal agencies. Reporting agencies also cited compliance with the stewardship, permitting, 

and enforcement provisions of the ARPA, and with the consultation, excavation, and discovery 

provisions of the NAGPRA, as ways they protected historic properties. 

Highlights:

›› NOAA’s Federal Preservation Officer (FPO) developed a working group of line offices 

and legal counsel to look at ways to improve NHPA compliance and develop policies on 

addressing undertakings with no potential to cause effect.

›› TVA reports that by the end of 2017 it completed eight modules for the entries in 

the Integrated Cultural Database, that will cover Section 106, Section 110, ARPA, 

NAGPRA, site protection, site monitoring, Corporate History (the extensive historic 

photo collection), and reinterment data.

›› The BLM Preservation Board (see Text Box) continues to meet twice a year to, among 

other tasks, review preservation issues and make recommendations to leadership on 

policies and procedures, training, and monitor and provide expertise to field offices’ 

historic preservation programs across the western states.

“The continued efforts to tailor Section 106 procedures to the Armed Forces Retirement Home 

(AFRH) have resulted in a more effective, efficient, and thorough preservation program.”

The BLM Preservation Board exemplifies how a land-managing agency can use an intra-agency working group to improve 

Bureau-wide consistency in preservation policies and procedures and enable field-to-headquarters communication using 

existing staffing. The Board is chaired by BLM’s FPO and includes Deputy Preservation Officers from each State Office. The

 field organization is represented by four officials authorized to make land-use decisions and two field office archaeologists. 

The BLM Tribal Liaison Officer fills out the Board, bringing the day-to-day, operational staff perspective. Their charge is to 

review issues and make recommendations to the Director and State Directors about policies and procedures, training, 

certification of field offices, monitoring of field offices’ historic preservation programs, and responses to public inquiries. 

In addition, the Board coordinates with the ACHP, NCSHPO, SHPOs, and THPOs.
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 27

Agency staffing to protect historic properties: 

Most agencies report that the number of their employees tasked with maintaining their 

preservation programs (to include Section 106 compliance) have stayed generally consistent, 

varying by agency size and mission. Several agencies, however, reported unfilled vacancies in 

their CRM departments that may or may not be filled due to personnel or budget limitations.

Highlights:

›› As the largest federal land-managing agency (approximately 245 million acres) reporting, 

BLM has 212 archaeology positions (“an average ratio of 1.5 million acres of public land 

per cultural specialist”).

›› Reclamation has 43 full-time employees for its 7.1 million acres of owned land and 

easements.

›› FWS has 18 full-time positions for about 145 million acres.

›› GSA has 27 full-time employees and eight additional qualified personnel.

›› NASA reports having prioritized the need for cultural resources training as a Procedural 

Requirements dictate resulting in individual Space Center CRMs either meeting the 

Secretary of the Interior’s Professional Qualification Standards or receiving baseline CRM 

training within six months of their assignment with requirements for additional training 

courses every year.

›› USACE’s Southwestern Division has acquired a Regional Planning and Environmental 

Center which provides centralized cultural resources services to four Districts.

Access to preservation training and expertise:

Two major changes in access to expertise since the last Section 3 report have been an increase 

in the number and variety of webinars and on-demand training courses offered by and to 

federal agencies, and an increasing use of in-house teaching expertise. Several agencies reported 

benefits from these opportunities. Reduced travel budgets and the growing sophistication of 

the online experience are primary reasons for the first trend, while the steady growth in agency 

CRM expertise accounts for the second. Many federal agencies also host annual or regional 

meetings of their CRM staff, either stand alone or in conjunction with the larger professional 

organizations (the annual meeting of the Society for American Archaeology has in the past 

hosted many multi-day federal agency archaeology personnel meetings) but this has been in a 

slow decline due, again, to tight travel budgets.

Highlights:

›› By mid-2018 NASA expects to have both general and advanced online training modules 

covering Section 106 review, tribal consultation, treatment of historic properties, writing 

Section 106 agreement documents, and working with historic districts.

›› During 2017, NPS partnered with the ACHP to provide Section 106 training for new 

superintendents and facility managers at 11 locations around the U.S.

›› VA partnered with the ACHP and SHPOs of Alabama, Ohio, and Nevada to host 

historic preservation training for its facility and planning staff and its Veterans Integrated 

Service Network staff. In addition, approximately a dozen VA staff from across the 

country report having taken individual preservation training during the reporting period.

›› USCG partnered with the ACHP to present three tailored Section 106 training courses 

to USCG personnel across country in 2016.
28 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

Among the most comprehensive mitigation efforts in GSA history are the research, recovery, 

education, and public access made possible by redevelopment of the National Historic Landmark 

St. Elizabeths [sic] hospital campus as the Washington, D.C. headquarters for DHS. GSA’s ongoing 

collaboration with the DC Preservation League (DCPL) and others to provide monthly public 

tours; a brochure; video-recorded oral histories; conservation and digitization of historic drawings; 

an extensive archaeological research, recovery, and management program; laser documentation of 

the west campus buildings and landscape; Historic American Buildings Survey (HABS) and Historic 

American Landscapes Survey documentation; and a generously illustrated 300 page online book on 

the history of St. Elizabeths Hospital, earned the agency a Washington, D.C. Mayor’s preservation 

award in 2014.

During 2015 construction, GSA discovered a 900-square-foot kiln used to make bricks for the 

1852 Center Building and its extensions. Preservation and project team members collaborated 

with DCPL to document the discovery in a short video with the project archaeologist explaining 

the excavation and how the kiln was used. The kiln and other discoveries will be identified in 

wayside interpretive signs for campus visitors and workers to enjoy.

CASE

STUDY

HEADQUARTERS 

CONSOLIDATION REVIVES 

ST. ELIZABETHS NHL 

WEST CAMPUS
In 2016-17, GSA collaborated with the National Building Museum to display artifacts, architectural 

elements, historic photographs, documents, and models of the evolving campus in an exhibit 

entitled Architecture of An Asylum: St. Elizabeths 1852-2017 (https://www.nbm.org/exhibition/

architecture-asylum-st-elizabeths-1852-2017/). GSA’s National Capital Region worked with 

museum curators to salvage building artifacts and locate items for exhibit selection and installation. 

Evocative displays include an iron-grilled doorway to a patient room; scrapbooks; letters; images 

of early electroshock equipment; dance therapy photographs from the 1960s; patient art; and a 

spectacular conserved 1904 model created for the St. Louis World’s Fair. Relics of the hospital’s 

past juxtaposed with images of recent development poignantly informed visitors about changing 

theories on how to care for the mentally ill and the government’s capacity for improving the 

quality of life for individuals and communities, culminating in the transformation of the 300-acre 

campus into a federal workplace, smaller hospital, and mixed-use urban development.

Opposite: Aerial view of St. Elizabeths campus, Washington, 

D.C. (photo courtesy U.S. Coast Guard)

Top: Center Building (black and white photo courtesy 

Library of Congress; color photo ACHP)

Center: Installation view of Architecture of an Asylum: St. 

Elizabeths 1852-2017 at the National Building Museum, 

Washington, D.C. (photo courtesy Yassine el Mansouri, 

National Building Museum)

Left: ACHP members on tour at the St. Elizabeths campus

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30 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

Successful partnerships that protect historic properties: 

The 2017 reports indicate that federal agencies are increasingly receptive to, and entering into, 

preservation partnerships to protect historic properties. These may be with another federal 

agency or with state or local governments, Indian tribes and NHOs, or private organizations. 

Some are short-term for a specific resource, while others are long-term protection or 

management relationships. Working to be better stewards with limited financial and personnel 

resources is the reason most often cited for these arrangements. It will become clear from this 

brief list that federal agency partnerships with others are critical to resource protection and 

must be fostered and encouraged. Such partnerships are especially important for agencies 

lacking specific kinds of expertise or stewardship capacity.

Highlights of partnerships among federal agencies:

›› Illinois: GSA and the USPS collaborated to restore and reunite two companion-New 

Deal murals in Chicago which had been separated since the 1980s. Strategically placed 

behind a glass façade, the former Chestnut Street Post Office murals are visible to 

pedestrians strolling by the post office building as well as customers inside.

›› Washington, D.C.: GSA worked with DOI to conserve and reinstall a 1938 Louis 

Bouche mural at the Stewart Lee Udall Building’s newly rehabilitated auditorium for the 

enjoyment of employees and visitors.

›› Florida: NASA has entered into a partnership with the FWS and NPS to manage 

archaeological resources in the northern portion of the Kennedy Space Center (KSC), 

which includes portions of the Merritt Island National Wildlife Refuge and the Canaveral 

National Seashore. In this area, NPS has the responsibility to research, interpret, and 

protect archaeological resources, including the curation of artifacts at the NPS’s Southeast 

Archeological Center. Projects with the potential to affect archaeological resources within 

the areas managed by FWS and/or the NPS are reviewed by KSC’s Center CRM prior to 

ground-disturbing activity to ensure that adverse effects are avoided.

Compliance with Section 106 was cited as the training most often taken. Of the 23 classroom 

training courses and 26 webinars the ACHP offered in 2016, about 80 percent of the 1,583 

participants were federal staff.

GSA In-House Preservation Training: Between 2015-2017 GSA said its own preservation 

experts provided in-house training on preservation compliance in seven of 11 regions, and on 

specific topics such as terra cotta evaluation and repair, sandstone conservation, survey and 

stabilization of stone capitals, innovative vertical access for repairs at substantial heights, and 

exterior brick investigation. This and three other programs leverage GSA’s in-house expertise, 

facilitate interaction between programs, and actively engage participants in resolving complex 

issues effectively.

The National Aeronautics and Space Administration Procedural Requirements for Cultural Resources Management is 

the principal policy document governing NASA’s CRM program. The document reflects NASA’s position that successful 

management and protection of historic properties–known and potential–requires consideration by numerous parties early 

in the planning process, well in advance of any physical activities.
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 31

›› Texas: USIBWC partnered with the NPS to provide archaeological monitoring and 

looting protection during the reconstruction of the levee system surrounding Fort Brown 

NHL. Current plans are for the NHL to eventually be transferred to the NPS and 

incorporated into the Palo Alto Battlefield National Historical Park.

›› Mississippi: USACE Mobile District partnered with the Department of Justice, FWS, 

and the United States Marshal Service to form a task force for protection of historic 

properties on Mobile District land. This led to a sharp decrease in looting and resulted in 

13 successful ARPA convictions.

Highlights of federal agency and state and local governments’ 

partnerships: 

These partnerships are important because they vest the community in the preservation of the 

historic properties and highlight the significance of the local connection.

›› Tennessee River Valley: TVA’s ARPA Investigations Team and Enforcement Program 

(commissioned federal investigators and specially trained archaeologists) focuses on 

patrolling and monitoring historic properties to reduce the destruction and removal of 

archaeological artifacts from TVA land through the criminal prosecution process outlined 

in ARPA. (Archaeological sites on TVA land, as well as on BLM and Reclamation’s lands, 

have continually been vulnerable to looting activity given their often close proximity to the 

water and remote location.)

›› South Carolina: Through a 2015 GSA loan agreement, the South Carolina Institute of 

Archaeology and Anthropology led the recovery of cannons from a sunken Confederate 

gunboat (C.S.S. Pee Dee) found in the Pee Dee River in South Carolina. The recovery is 

documented in an online video (https://www.youtube.com/watch?v=ZBhPa3sAV0M) 

made prior to conservation of the cannons that will be displayed at a local VA facility.

›› Maryland: At the NPS Antietam National Battlefield, 1,878 volunteers donated 28,761 

hours of their time during FY 2016. In terms of estimated dollar value, these volunteers 

provided more than $677,600 of service to the park. While much of the total volunteer 

hours benefited major events such as the Battle Anniversary weekend when the park 

received more than 5,000 visitors, the park also received 722 hours of volunteer time in its 

museum and library.

The USACE partners with various cooperating associations to provide resources and volunteers 

in the protection and interpretation of historic properties. In 2016, 174 USACE operating projects 

conducted interpretive programs for 30,037 visitors on-site, and 13,500 contacts at off-site 

programs at schools and other community venues.

The NPS Volunteers-in-Parks (VIP) program is authorized by the Volunteers-in-Parks Act of 1969. The purpose is to provide 

a means through which the NPS can accept voluntary help from interested citizens and international visitors in a way that 

is mutually beneficial to the NPS and to the volunteer. In 2016, more than 339,000 volunteers donated 8.06 million hours of 

service to national parks, including more than 351,000 hours toward cultural resources management. There are more than 

390 volunteer programs throughout the National Park System, and the numbers of volunteers and hours has grown an average 

of 5-7 percent annually since 1990.
32 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

›› Nevada: Reclamation’s Lower Colorado Regional Office works in partnership with the 

Southern Nevada Water Authority and the Clark County Department of Parks and 

Recreation to manage, preserve, and interpret cultural resources along Las Vegas Wash 

within the Clark County Wetlands Park.

›› Wyoming: BLM’s Wyoming Newcastle Field Office partnered with a Wyoming 

Conservation Corps team to remove fire killed trees and deadfall from areas near 38 

petroglyph panels to protect them from future wildfires and clear access along walking 

routes used on public tours. The crew also removed tangled fencing and fence posts that 

had been uprooted during a flash flood, which had hindered access to a large petroglyph 

panel.

›› New Mexico: In 2014 the USACE’s Albuquerque District implemented the “Cerrito 

Recreation Area Site Protection Measure Study,” in partnership with the New Mexico 

SHPO and tribes at Abiquiú Lake, to address recreational access and impacts to historic 

properties. This will provide valuable data to resource managers regarding effective site 

protection measures in high traffic areas.

Highlights of federal agency and tribal partnerships: 

There is significant room for more varied partnerships with tribes. Tribes can be especially 

effective partners; they have special expertise about what makes a property significant, and 

often have strong historical and cultural connections with them. Federal agencies report very 

few historic preservation partnerships with NHOs. 

›› New Mexico: Reclamation partnered with the Nambe, Pojoaque, San Ildefonso, and 

Tesuque Pueblos to complete four large archaeological surveys of the impact corridors for 

the Aamodt Project, a large project to deliver water to four New Mexico pueblos.

›› Pacific Northwest: USACE’s Portland District partners with the Columbia River InterTribal Fisheries Enforcement (CRITFE) department to patrol more than 150 miles of 

shoreline on the three lower Columbia River reservoirs, resulting in reduced looting of 

historic properties. CRITFE also provides training to local law enforcement, park rangers, 

and tribal members.

BLM Ethnographic Outlaw Cave, 

Montana (Photographs courtesy 

of Chief Dull Knife College, 

provided by BLM)
BLM continues a 20-year partnership with the SHPOs of 

Alaska, Arizona, California, Colorado, Idaho, Montana, Nevada, 

New Mexico, Oregon, Utah, and Wyoming that makes 

historic property data available to other federal agencies, 

Indian tribes, consultants, and academics. The Cultural 

Resources Data Partnership (CRDP) includes financial 

support to SHPOs to maintain statewide inventories and 

allows technical support between SHPOs and the BLM. 

The geographic information data describes information 

on historic properties of all types, including archaeological 

sites, historic structures, TCPs, and cultural landscapes. The 

project involves digitizing and automating BLM site records, 

locations, and surveyed space and making this information 

widely available and usable by multiple entities. The goal is 

to invest in developing the SHPO data management systems, 

pursuant to the NHPA, creating a shared inventory of 

cultural resources data, rather than having BLM also maintain 

a separate inventory, which significantly reduced costs and 

redundancy. 

Chairman’s award

For Federal aChievement

in historiC Preservation

presented to the

U.S. Department of the Interior Bureau of Land Management

for the Cultural Resources Data Sharing project 

operating in 11 western states in conjunction

August 19, 2009

John L. Nau, III, Chairman

with their State Historic Preservation Officers

The data-sharing project began in 1998 as a provision of the 

nationwide Programmatic Agreement between the BLM, the 

ACHP, and NCSHPO. At that time, it was viewed as a fiveyear project but has evolved into a long-term partnership 

between the BLM and the 11 western states where BLM has 

significant land managing responsibilities.

In 2008, the CRDP received the Special Achievement 

in Geographic Information Systems award from ESRI (a 

pioneering GIS software company) for data sharing that is 

propelling BLM and the SHPOs into managing thousands of 

public lands’ cultural resource sites uniformly, cohesively, 

and comprehensively. In 2009, the project received the 

ACHP’s Chairman’s Award in recognition of a combined 

effort among the BLM and the SHPOs that enables cultural 

resource professionals to have consistent, reliable, easy-touse spatial information systems on their desktop computers 

to support informed federal decision making. The CRDP 

demonstrates how federal and state interests can work 

together to advance shared objectives for the common good 

of resources and streamlined and efficient business practices.

ACHP Chairman’s Award certificate from 2009

Cultural Resources Data Sharing Partnership poster (courtesy BLM)

BUREAU OF LAND 

MANAGEMENT DATA 

SHARING PARTNERSHIP

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Indian tribes have occupied northern Alabama for millennia, and for 600 of those years, a pair of 

bluffs overlooking the Tennessee River in Marshall County have provided a glimpse into their history. 

Although visible for ages, etched and painted images on the “Painted Bluff,” as the site has come to 

be known, were first documented the 1823 book The Natural and Aboriginal History of Tennessee.

The movement of settlers into the area during the 19th century resulted in displacement of the 

original inhabitants. As a consequence, many of the tribes that originally occupied this area have 

moved further south and west, but their ancestral, cultural, and spiritual ties to the traditional 

cultural and sacred places in this area remain strong. As the centuries wore on, impacts from man 

and nature alike took their toll on the sacred images. The effects of modern-day graffiti on the more 

than 80 animal effigies, ovals, circles, and other abstract symbols were documented in the 1950s.

In 2004, a team of archaeologists from the University of Tennessee noted that, in addition to damage 

from vandalism and rock climbing at Painted Bluff, humidity and erosion were causing pictographs at 

the NRHP-eligible site to chip and flake away.

The Painted Bluff overlooks land at TVA’s Wheeler Reservoir. The agency worked with the Alabama 

Historical Commission to have the site named to its 2013 “Places in Peril” list, highlighting the 

state’s most endangered landmarks.

TENNESSEE VALLEY 

AUTHORITY PARTNERS 

TO PROTECT ROCK 

SHELTER ART

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The following year, TVA hired consultants to study the damage to the site. They recommended a 

multi-faceted approach to address the problem, including removal and camouflaging of the existing 

graffiti, along with public outreach and volunteer involvement. With the removal and camouflage 

plan in hand, TVA initiated a Section 106 review with the SHPO and 15 federally recognized 

tribes that have ties to Painted Bluff as part of a broader commitment to protect and provide 

stewardship for these important places. The tribes recommended that images impacted through 

natural weathering be left alone, and that the focus of any remediation work should be on human 

impacts to the site—in particular, those caused by rock climbing. 

In 2014, TVA worked with the consultants and community volunteers from northern Alabama and 

University of Alabama students to catalog, remove, and disguise the damage at Painted Bluff. Graffiti 

50 years or older was left in place pending further research, while disturbances less than 50 years 

old were removed or camouflaged. 

Ultimately, graffiti was remediated at more than 120 different surfaces. Next, TVA collaborated 

with the Southeastern Climbers Coalition to close climbing routes located along the bluff, and to 

install signs alerting climbers of the closures. Finally, TVA used Painted Bluff as a proving ground 

for an archaeological site monitoring program called “A Thousand Eyes.” Volunteers went through 

the program training course, and then recorded data on the site that was submitted to TVA. The 

agency continues to work with the historical commission and student volunteers to protect and 

monitor the site.

Opposite: Painted Bluff from 

a distance, Marshall County, AL 

(photo courtesy Alan Cressler)

Dancing human image, graffiti 

removal at Painted Bluff (photos 

courtesy TVA)

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Highlights of federal agency and non-governmental partnerships:

Historic properties benefit from having private partnerships with knowledgeable 

organizations concerned with their preservation. Such partnerships benefit federal agencies 

by providing often no (or low) cost expertise and personnel to help preserve and tell the 

story of the property, while giving those concerned with its future a voice and stake in its 

continued existence. 

›› Texas: The Federal Aviation Administration (FAA) partnered with the Texas Air and 

Space Museum to complete the display of its historic Douglas DC-3 Aircraft, which had 

a significant role in the development and modernization of flight inspection standards and 

aircraft design.

›› Washington, D.C.: AFRH partnered with the National Trust for Historic Preservation’s 

President Lincoln’s Cottage at the Soldiers’ Home to enhance heritage tourism and 

educational programs for the campus.

›› VA has entered into two formal agreements to permit external fundraising for specific 

historic preservation projects: at VA Medical Center (VAMC), Dayton, Ohio, which was 

selected to host a Departmental history center, a community coalition will fundraise to 

rehabilitate Buildings 116 and 129; and at Greater Los Angeles Healthcare System, the 

1887 Fund will fundraise to rehabilitate five West Los Angeles VAMC campus buildings, 

including a long-vacant chapel.

›› Florida: FWS has partnered with the University of Florida to conduct archaeological 

investigations at Lower Suwannee and Cedar Key National Wildlife Refuges as part of 

a long-term scientific research partnership.

›› The West: BLM partners with museums and universities to manage its collections 

and maintains three unique repositories: the Anasazi Heritage Center (Colorado), the 

Curation Center (Montana), and the National Historic Oregon Trail Interpretive Center 

(Oregon).

›› Washington, D.C.: Department of the Treasury partnered with the Treasury Historical 

Association, which provided funding for the restoration of the Treasury Building’s West 

Stair balustrade and for the conservation of objects in the Treasury Collection.

›› VA’s National Cemetery Administration is working with Friends of Historic Jefferson 

to rehabilitate the Jefferson City, Missouri, lodge, and with the Wilmington Historical 

Society to rehabilitate the Wilmington, North Carolina, lodge.

›› The West: BLM’s Site Stewardship Program is active in almost every state where BLM 

has a presence. Some states like Arizona and California have been working with volunteer 

stewards for decades. After archaeological field training, steward volunteers record new 

sites and monitor previously discovered sites, providing important support for Section 110 

responsibilities. 
NASA RESTORATION OF 

MISSION CONTROL CENTER

Johnson Space Center (JSC) is restoring its Apollo Mission Control Center (MCC) NHL back to 

its appearance during the moon landings. In 2014, the NPS expressed concerns about the NHL’s 

future, resulting in a partnership formed among JSC, the non-profit Space Center Houston (SCH), 

and the City of Webster, Texas, with support from the ACHP, the Texas SHPO, NPS, the National 

Trust for Historic Preservation (NTHP), and retired Apollo Program flight directors to restore 

the Apollo MCC to its late 1960s appearance. The restoration will be carried out with the aid of a 

historic furnishings report prepared by the NPS. Section 106 consultation in April 2017 resulted in 

a no adverse effect determination with concurrence from all consulting parties. Execution of the 

project has been enabled by the fundraising efforts of SCH (an affiliate of the Smithsonian), with 

a significant donation from the City of Webster, which seeks to promote heritage tourism in the 

area. Because NASA is prohibited by law from accepting private funds, the cost of the restoration 

is through a transfer of funds from SCH to the ACHP, which does have the authority to accept 

donations of money, equipment, and other resources from public and private parties to assist 

federal agencies in the preservation of their historic properties. This authority came about through 

1976 amendments to the NHPA and was further extended in 2003 by President George W. Bush, 

as part of the Preserve America EO. The NASA award is the first such use of the authority and 

highlights the benefits and opportunities available through public-private partnerships. The ACHP 

hopes to encourage more such usage of this donations authority in the future. 

Apollo Operations Mission 

Control Room, Johnson Space 

Center 1969, Houston, TX 

(photos courtesy NASA)

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Using Section 106 program alternatives to manage and protect 

historic properties. 

Compliance with Section 106 was cited by numerous respondents as their primary mechanism 

to protect their historic properties. While some agencies utilize the standard review process 

set out in the ACHP’s regulations (36 CFR §§ 800.3-7), others find it advantageous to use a 

tailored approach. Section 800.14 of the ACHP’s regulations lays out these tailored approaches 

to meet agency Section 106 obligations and preservation challenges. The ACHP specifically 

asked for information regarding this trend to determine the extent to which agency use of 

program alternatives assisted them in better protecting and managing their historic properties. 

This will in turn assist and inform the ACHP in determining whether to devote additional 

resources to their propagation and use.

The two most common program alternatives are Programmatic Agreements (PAs) and 

Program Comments. While most federal agencies use Programmatic Agreements on a case-bycase basis to address complex projects, several large land-managing agencies have used them to 

implement a consistent approach to NHPA compliance across the country. A greater number 

have used Programmatic Agreements to tailor Section 106 review to the management needs of 

specific regions or units.

Agencies independently reported that time invested in developing and negotiating PAs 

has been well spent and determined that the agency can comply with the requirements of 

Section 106 in a more effective and efficient manner in a variety of ways. These include 

institutionalizing activities that are similar and repetitive in nature, by stipulating roles and 

responsibilities, excluding certain categories from further Section 106 review, establishing 

protocols for consultation to facilitate the identification and evaluation of historic properties, 

and streamlining the resolution of adverse effects. These innovative comprehensive approaches 

could be used as a model by land-managing agencies in identifying locations suitable for energy 

development while considering effects to historic properties, thus increasing predictability for 

both project sponsors and consulting parties.

Highlights:

›› In 2016, BLM California executed a PA with the California SHPO and the ACHP for the 

Desert Renewable Environmental Conservation Plan. The Plan directs possible siting for 

future utility scale renewable energy projects on BLM-administered lands in the southern 

California deserts. Consultation included outreach with 45 federally recognized tribes; 

seven tribal organizations; 89 federal, state, and local agencies; 42 academic institutions/

museums/historical societies; 29 industry representatives; 72 other organizations; and five 

individuals. Key aspects of the PA include cultural resource sensitivity analyses intended 

to inform siting decisions and to start project specific discussions early between consulting 

parties; a scientific peer review process; a cultural resource training program; and a 

regional compensatory mitigation program addressing cumulative effects.

›› In 2016, GSA’s Rocky Mountain Region became the fourth among 11 regions to negotiate 

a multi-state PA, reducing GSA’s compliance workload for routine repairs at historic 

buildings. The PA has already cut the region’s Section 106 correspondence by 55 percent. 

Half of GSA’s historic building inventory (by number and statewide coverage) now 

benefits from streamlined compliance through regional PAs.
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PARTNERSHIP SAVES 

HISTORIC LIGHTHOUSE

Many of GSA’s most noteworthy compliance successes result from partnerships that GSA initiates 

or substantively guides. The Gay Head Lighthouse in Martha’s Vineyard has special significance to 

the community and nation as the only lighthouse with a history of Native American lighthouse 

keepers. For decades, it was owned by the USCG and maintained by the Martha’s Vineyard 

Museum. The light within the tower continues to guide traders, fishermen, cruise ships, and 

recreational boaters today.

When erosion of the Gay Head Cliffs threatened catastrophic loss of the lighthouse, GSA led 

negotiation among five consulting parties resulting in a Section 106 Memorandum of Agreement 

detailing all conveyance responsibilities in time to relocate the lighthouse 50 feet inland before 

the onset of the summer storm season. The town of Aquinnah, Massachusetts, agreed to complete 

photo documentation of the lighthouse and to place interpretive signage at the site of the 

lighthouse’s former foundation. Aquinnah and the Martha’s Vineyard Museum agreed to rehabilitate 

and maintain the lighthouse, operating it as a museum again.

The move drew national attention and was featured in a NOVA episode (https://www.youtube.

com/watch?v=wmQO3ahvCwI&t=1sand). CNN named Gay Head one of the five biggest 

preservation “wins” of 2015. GSA’s subsequent collaboration with the ACHP to document the 

undertaking in a “106 Success Story” (http://www.achp.gov/docs/gay-head-lighthouse.pdf) will 

benefit future conveyances requiring cooperation among several organizations to preserve historic 

property at risk.

Moving the Gay Head 

Lighthouse, Aquinnah, MA (top 

photo courtesy Derrill Bazzy; 

bottom photo courtesy Drew 

Kinsman)

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The challenge of protecting widely dispersed historic resources. 

Several agencies, including Reclamation and NOAA, specifically noted that historic properties 

spread over vast areas of land or water presents a unique management challenge. Reclamation 

sums it up best: “protection of archaeological properties continues to be difficult given the 

large inventory of widely distributed sites, often in remote locations or with difficult access, 

and budget and staff limitations that by necessity focus time and funding upon Section 106 

compliance.”

NOAA cites the diverse and widespread positioning of its properties as a challenge for 

property management, which relates directly to limited staff to address historic preservation 

issues. NOAA’s Papahanaumokuakea Marine National Monument is one of the largest marine 

conservation areas in the world (and a World Heritage Site), and contains both terrestrial 

and underwater historic properties—shipwrecks, archaeological sites on both land and in 

the water, and places of traditional cultural importance to the Native Hawai’ian community 

and Pacific Islanders. FWS also is responsible for administering far flung resources: seven 

National Wildlife Refuges (NWR) in the Pacific Remote Islands Marine National Monument, 

including Baker Island NWR, Howland Island NWR, Jarvis Island NWR, Johnston Atoll 

NWR, Kingman Reef NWR, Palmyra Atoll NWR, and Wake Atoll NWR.

These agencies, along with BLM and TVA, note that current allocations are typically only 

sufficient to address problems brought to their attention.

The majority of negotiations for the CBP’s Northern and Southwest Border PAs focused on 

reducing the review of routine and repetitive activities that have been found to not adversely affect 

historic properties’ NRHP qualifying characteristics.

VA executed a statewide Programmatic Agreement for 10 medical centers in Florida in 

2015 to increase compliance efficiency and focus preservation review on the single historic 

medical campus.

From BLM’s 2017 report: “The BLM’s national Programmatic Agreement with the ACHP and 

NCSHPO is a critical mechanism for achieving efficiencies in the Section 106 review process. 

In addition, the tools and processes developed by the Cultural Resources Management Program 

streamline the compliance process, providing flexibility and cost-savings for the bureau and 

land-users.”

In 2017, the ACHP issued the Program Comment for Telecommunications Infrastructure on Federal 

Property, developed through an interagency effort led by DHS, to expedite Section 106 compliance 

for the installation of broadband technology on federal lands addressing regulatory barriers and 

encouraging investment and training in order to provide access to broadband services for tribal, 

rural, and underserved communities. It is currently applicable to all DHS Components and the NPS, 

Forest Service (FS), Bureau of Indian Affairs (BIA), Rural Utilities Service (RUS), and BLM.
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Federal agencies were asked to share with the ACHP and Secretary of the Interior information 

on how they used their historic properties between 2014 and 2017. They were asked how this 

use contributed to local communities through economic development and heritage tourism, 

and if partnerships assisted; how they achieved resiliency goals; their success at leasing excess 

buildings and structures; and, the potential impacts of several recent federal laws aimed at 

further “reducing the footprint.” 

OVERVIEW: 

Federal agencies as a whole continue to make efforts to use their historic buildings for mission 

needs, and have a variety of mechanisms at their disposal with which to do this. Where feasible 

rehabilitation to meet “green” or LEED standards is now more common than it was in the last 

reporting period. Leasing and reuse are especially important as properties in use are better 

maintained and cared for, can be made energy efficient and green, and often were built to high 

construction standards (an underappreciated reason for their continued existence). Agencies 

like GSA and NASA (and now the VA) continue to find innovative ways to lease out unused 

or unneeded facilities or space.

Cost Savings and “Reduce the Footprint” Goals. 

Per Office of Management and Budget (OMB) Management Procedures Memorandum 

2015-01, Implementation of OMB Memorandum M-12-12 Section 3: Reduce the Footprint, 

dated March 25, 2015, all Chief Financial Officers (CFO) Act executive branch departments 

and agencies are required to “aggressively to dispose of surplus properties held by the Federal 

Government, make more efficient use of the government’s real property assets, and reduce the 

USING HISTORIC 

PROPERTIES

CHAPTER 4

United States Coast Guard 

Cutter Eagle under full sail 

(photo courtesy U.S. Coast 

Guard)
42 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

total square footage of their domestic office and warehouse inventory relative to an established 

baseline.” Through strategic planning, reinvestment, and consolidation, agencies continue 

to use historic properties to achieve their “Reduce the Footprint” goals. For example, GSA 

reported to the ACHP that during the 2015-2017 period, it initiated 49 projects that will save 

federal taxpayers and 26 agencies more than $47 million in projected rents at federal facilities 

across the nation. Many of these projects consolidate federal tenants in historic buildings 

or enable agencies to use them more efficiently with mobile workplace technology and space 

sharing solutions. 

GSA has also worked closely with the Administrative Office of the U.S. Courts, one of their 

major tenants, to rethink planned expansion projects wherever opportunities exist to costeffectively reuse government-owned buildings. This reduces the amount of new construction 

required to accommodate increased caseloads. Twelve projects will consolidate federal tenants 

in historic public buildings to reduce the government’s reliance on leasing and shrink the 

federal real estate footprint. Major modernizations and consolidations completed during the 

previous reporting period are yielding taxpayer savings, according to GSA. In addition, energy 

use data show significantly increased benefits when agencies vacate costly leased space for 

federally owned historic buildings that have been rehabilitated for improved energy savings 

and space efficiency. 

As recommended in GAO studies, GSA is now broadening the scope of courthouse expansion 

funding requests to include plans for reuse, reprogramming, or disposal of existing courthouse 

facilities, giving preference to alternatives that reuse historic buildings, when feasible. The 

2016 courthouse program includes funding for rehabilitation and annex construction that will 

supplement, rather than replace, three monumental historic courthouses, so they may remain 

in use and serving the purpose for which they were built. These iconic buildings have served 

the courts well for upwards of 85 to 123 years.

Contributing to local communities through economic development 

and heritage tourism.

An important component of federal policy (e.g., EO 13006: Locating Federal Facilities on Historic 

Properties in Our Nation’s Central Cities 1996 http://www.achp.gov/EO13006.html) and the 

Preserve America EO [http://www.preserveamerica.gov/Executive%20Order%2013287.pdf ] 

is the emphasis on location of facilities in central cities and downtown areas, to maintain a 

convenient “federal presence” and strengthen the vitality and livability of the communities 

and, where possible, foster heritage tourism. Reuse of historic buildings and structures is 

efficient, supports preservation, and has been shown to be good for the livability and economy 

of local communities (see also EO 12072, Federal Space Management, 1978 [https://www.

archives.gov/federal-register/codification/executive-order/12072.html]; EO 13693 [https://

www.fedcenter.gov/programs/eo13693/]; and Department of Transportation, Implementing 

Instructions-Sustainable Locations for Federal Facilities, 2011 [https://www.fedcenter.gov/_

kd/Items/actions.cfm?action=Show&item_id=19447&destination=ShowItem]).

VA Secretary David Shulkin announced in June of 2017 a plan to dispose of all vacant VA buildings 

in 24 months (either by demolition or reuse). VA’s list of 400+ vacant and 750+ underutilized 

properties include a significant portion of NRHP-eligible or listed historic properties. VA is 

currently in the initial stages of framing a Section 106 Program Comment to address this challenge.
NATIONAL PARK SERVICE 

CONSOLIDATES AT SIGNATURE 

HEADQUARTERS BUILDING

In 2017, the NPS consolidated its cultural resources programs including, among others, the NRHP, 

the Historic American Buildings Survey, and Heritage Preservation Services, to reunite with other 

DOI programs in the 1936 Main Interior building for the first time in a half-century. Now named 

the “Stewart Lee Udall Department of the Interior Building,” this New Deal icon once again 

provides a consolidated headquarters and federal presence that is vividly tied to the agency’s 

mission. Buffalo motifs decorating its doors, Native American murals rimming its sky-lit cafeteria, 

and an extensive collection of WPA murals promotes the DOI programs and conservation 

philosophy to visitors and employees traversing the building’s corridors and stairways. Clad in 

Indiana limestone, with interior public spaces finished in durable Tennessee marble, the building 

was conceived for functional adaptability and long-term value. It was among the government’s first 

buildings to include movable steel partitions, acoustically treated ceilings, fire-proofing, central 

air conditioning, a central vacuum system, and a floor reserved for mechanical equipment. The 

six-phase rehabilitation project, undertaken by GSA, the building’s owner, built upon the building’s 

inherently sustainable attributes, adding green roofs and solar panels for renewable energy.

Counterclockwise: Stewart Lee 

Udall Department of the Interior 

Building, Washington, D.C. Replanting 

the Wasteland, by Ernest Fiene 

(photo courtesy Carol M. Highsmith 

Photography, Inc./GSA)

The mural is rolled onto a large 

cardboard tube to facilitate its 

removal from the wall and for safe 

transport to the conservation lab. 

(photo courtesy U.S. Department of 

the Interior Museum)

A conservator working on the 

Henry Varnum Poor fresco in the 

DOI headquarters building (photo 

courtesy U.S. Department of the 

Interior Museum) 

“American Bison” by Boris Gilbertson, 

1940, restored (photo courtesy U.S. 

Department of the Interior Museum)

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DEPARTMENT OF VETERANS 

AFFAIRS CREATES 

ADDITIONAL HOUSING FOR 

HOMELESS VETERANS

The West Los Angeles VAMC has been serving veterans since 1888 when it was the Pacific Branch 

of the National Home for Disabled Volunteer Soldiers (NHDVS). It covers more than 400 acres 

along Wilshire Boulevard. 

The campus has evolved dramatically over the years alongside veteran medical care. Architect 

Stanford White designed the Pacific Branch featuring wood buildings in the Shingle style. Some 

original buildings exist today, but most were replaced throughout the 1920s-1940s when the 

campus underwent a tremendous transformation as part of the VA Second Generation building 

campaign. Triggered in response to the increased veteran populations, the campaign changed 

the Branch into a planned campus featuring Mission Revival style architecture with connecting 

landscapes and open spaces. The Mission Revival-style Building 209 was constructed of reinforced 

concrete finished in smooth stucco with a terra cotta tile roof. West Los Angeles VAMC was listed 

on the NRHP in 2014, with the historic district representing an excellent, intact example of a 

Second Generation veterans hospital built upon the campus of the first NHDVS branch on the 

west coast.

In 2011, the VAMC proposed to rehabilitate Building 209, at the time vacant, to provide long-term 

supportive residential housing for homeless veterans. The project would include seismic upgrades 

and a major renovation of the existing building. Recognizing that Building 209 was a contributing 

resource to the historic district, the VAMC consulted with the California SHPO on the effects of 

the proposed project on the historic property. While the rehabilitation would retain most of the 

building’s contributing features by adhering to the Secretary of the Interior’s Standards, the original 

metal windows would be replaced, causing an adverse effect on the property. Through additional 

Section 106 consultation an approach was found that would preserve the steel frames and sashes 

while replacing the existing glass with a new laminated glass, thereby addressing the energy 

performance requirements. With this solution, the VAMC was able to preserve the building and its 

historic elements, avoiding adverse effects altogether.

Opened in 2015, Building 209 provides housing and healing space for homeless veterans. It is an 

award- winning rehabilitation project that supports VA’s mission of caring for the nation’s veterans.

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Opposite: Building 209 at West Los Angeles VMAC, rehabilitated exterior from 

historic parade field (photo courtesy Lawrence Anderson Photography)

This page: Rehabilitated lobby, refurbished windows, residential unit, main 

entrance (photos courtesy Lawrence Anderson Photography)
46 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

The reports received demonstrate that federal agencies accept these principles of location, 

reuse, and sharing their history with the public. GSA noted it has found that opportunities 

to lease space in nonfederal historic buildings most commonly arise when federal agency 

space requirements are modest enough to be accommodated in a historic building. If an 

agency needs more space and federally owned facilities are not available, this usually requires 

leasing in contemporary buildings or new construction. Many GSA leases in commercial 

historic buildings are located in rural towns or small cities where rental rates for leased office 

space are low compared to rates for office space in metropolitan areas. One urban location 

where leases in historic buildings cost-effectively supplement federally owned space is 

Philadelphia, Pennsylvania. In 2016, GSA’s Mid-Atlantic regional headquarters relocated to 

the historic mid-century Rohm and Haas Headquarters building near Independence Mall. 

After redesigning the leased workspace to reduce its headquarters footprint, GSA successfully 

backfilled the unoccupied space by relocating Census and VA offices from expiring leases in 

non-historic buildings to the Rohm and Haas Building. Concurrently, Health and Human 

Services downsized from a lease of 102,231 usable square-feet in the historic Public Ledger 

Building to 79,772 usable square-feet vacated by GSA’s regional headquarters in the nearby 

historic Strawbridge and Clothier Building. A longtime shopping destination occupying 

2.1-acres in the heart of the city’s retail district, the historic department store building features 

a helipad, patios, marble lobby, and 12-15-foot ceilings.

Most responding agencies promote their historic properties where consistent with agency 

missions, and some agencies, like the NPS, FS, and BLM, include heritage tourism in their 

mission and land management strategies. Federal agencies responding provided examples 

that demonstrate a broad range of innovative and enduring ways they contribute to local 

communities and provide opportunities for the interested public to learn about the nation’s 

collective history.

Many historic buildings and structures have been modified to serve successive programs and 

missions. Consistent with the ACHP’s guidance on highly technical and scientific historic 

properties (http://www.achp.gov/docs/consideration-highly-technical-scientific-facilities.pdf ) 

and NPS guidance on special categories of resources such as movable and aviation historic 

properties, federal agencies view this continual process of modification to be a characterdefining feature of historic properties. Physical and operational security requirements impact 

the management of federally owned historic properties. In those cases, these considerations 

limit the opportunities for a federal agency to provide public access to its facilities.

The qualifiers “consistent with agency mission” and “conflicts with agency mission” can have 

major effects on agency use of, and public access to, federal historic properties. Some reporting 

agencies like DHS said the nature of their missions or function of historic properties 

precluded active contributions to tourism or the local economy. Smaller agencies with very 

specific missions (e.g., Department of Labor, National Institute of Standards and Technology, 

BOP) faced the greatest challenge in this regard. They noted that by virtue of their presence 

in a community they were contributing to the local economy through employment and the 

acquisition of goods and services, but that opportunities for heritage tourism or visitation 

were limited at best. DHS said heritage tourism was not consistent with its mission or the use 

NASA reports it is considerably less expensive to modify an existing building or structure than 

it is to construct new. NASA estimates 93 percent of its identified historic properties are in active 

use either by NASA or a tenant, and approximately 10 percent of historic properties are leased.
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 47

of facilities. Opportunities for heritage tourism related to DHS facilities (as well as military 

installations and many Department of Energy [DOE] facilities) are limited due to security 

concerns which DHS does not anticipate changing. However, many agencies have robust use 

and visitation programs.

Highlights:

›› While it pursues on- and off-site opportunities to inform the public about its historic 

properties and foster heritage tourism, Reclamation reports the agency lacks a system 

for tracking visitation. However, the following examples illustrate how Reclamation is 

promoting heritage tourism and interpreting the historic significance of communities:

• To make the sites more accessible without creating security and safety concerns, 

Reclamation and NPS partnered with CyArk to create a virtual tour of the historic 

Shoshone Powerplant at Buffalo Bill Dam, Wyoming, available to view on YouTube 

(https://www.youtube.com/watch?v=0MvabiF-zXw);

• The Montana Area Office renewed a special use permit allowing the Fairfield, Montana, 

Chamber of Commerce to use the historic Greenfields Irrigation District office 

building for a local museum and RV parking;

• The Dakotas Area Office installed interpretative signage at the former location of the 

Daniel Winter House, at the Lonetree Wildlife Management Area, North Dakota. 

Using text and HABS photography, the sign presents information on the unique 

puddled mud architecture used by early 20th century German-Russian homesteaders in 

the area.

›› The VA’s two oldest buildings, both dating from ca. 1750, were recently renovated by the 

VA Medical Center Perry Point, Maryland. Building 501, the Mansion, will continue to 

be used for staff training, and formerly vacant Building 504, the Mill, will now house a 

museum interpreting the site’s history.

Partnerships in using historic properties: 

Federal agencies continue to report diligent efforts to partner with other federal agencies, state 

and local organizations, Indian tribes, and private organizations to share the knowledge and 

experience of federal historic properties with the public. Judging from the attendance numbers 

some agencies provided, the interest in these properties out there is vast and growing.

BLM visitor data for FY15 indicated 3,412,888 visits to cultural sites; in FY16, that number increased almost a quarter-million to 

3,637,818. Recreation on BLM lands contributed from more than $162 million to more than $186 million to local economies.

In 2016, 331 million visitors came to the national parks—America’s special places cared for by the NPS family of 22,000 

employees and 221,000 volunteers. In addition to spending the day exploring history and experiencing nature, national park 

visitors also spend money in nearby gateway communities helping to fuel local economies. An NPS report, 2016 National Park 

Visitor Spending Effects: Economic Contributions to Local Communities, States, and the Nation, underscores the fact that national 

parks play a major role in attracting and sustaining local businesses and communities. According to the report, which was 

prepared by economists Catherine Cullinane Thomas of the U.S. Geological Survey and Lynne Koontz of the NPS, in 2016 

visitors spent more than $18.4 billion in communities near national parks, a sum that translates into 318,000 local jobs. 
TENNESSEE VALLEY 

AUTHORITY DAM 

CELEBRATES BIRTHDAY

TVA’s Norris Dam 80th birthday celebration allowed the agency to connect directly with the local 

community and tell the story of its past and present through multiple activities. TVA was created 

in 1933 to improve the quality of life of the people of the Tennessee Valley through flood control, 

improved navigation, and affordable electricity. TVA’s system of locks and dams is the tangible symbol 

of the agency’s mission of service to improve life in the region. As part of the “Built for the People” 

campaign, TVA highlighted a major milestone for the first dam TVA built, Norris Dam, located on 

the Clinch River in east Tennessee. Agency staff hosted a family friendly celebration highlighting the 

anniversary of 80 continuous years of operation of this magnificent structure. The two-day public 

celebration featured a rare opportunity for the public to tour the Norris Dam Powerhouse, viewing 

the generators and the control room. They were allowed on the wing wall to view the massive 

spillway of Norris. Also as part of this event, TVA set up more than 20 tents of activities for the 

public to learn more about the agency. TVA partnered with the Knoxville Track Club to host “The 

Big Dam Race” which was an 8 km race across the top of Norris Dam. The target audiences were 

members of the general public served by TVA, TVA customers including local power distributors, 

and TVA employees and retirees. The event targeted a cross section of the public from baby 

boomers whose parents or grandparents helped build the dam to younger people and children not 

as familiar with TVA’s history. The extensive media coverage generated a huge turnout—more than 

30,000 people visited Norris Dam that weekend and learned about TVA’s history.

Norris Dam 80th birthday public 

celebration (photos courtesy TVA)

left: Students from Vassar College in 

1946 beginning a 10-day study of TVA 

and inspection of its projects. The 

field trip to Norris Dam was part of 

a new 10-week course, “The TVA—

A Study in Regionalism” offered by the 

college. (photo courtesy TVA)

CASE

STUDY

48 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 49

Highlights:

›› USCG continues its active partnership with GSA and NPS in ensuring the success of the 

National Historic Lighthouse Preservation Act (NHLPA), with 10 historic lighthouses 

entering into this program over the reporting period. The NHLPA program enables 

local communities to promote heritage tourism by transferring the ownership of historic 

lighthouses to new owners who rehabilitate and restore them as properties available for 

public visitation. 

›› As the primary point-of-access for the general public, NASA’s Visitor Centers represent 

a successful and high-priority partnership for the agency. Operated by private entities and 

located on or adjacent to NASA Centers, Visitor Centers provide a venue outside of the 

standard security requirements for the agency to receive and present information to the 

public. KSC and JSC are perhaps the most well-known and most visited of the NASA 

Centers, and their presence has contributed significantly to heritage tourism in their 

respective geographical areas.

Meeting federal resiliency goals. 

Some agencies did not identify resiliency or sustainability, defined as “the capacity to recover 

quickly,” as significant issues in this reporting cycle. Most agencies did, however, note the 

importance of federal infrastructure resiliency and had made efforts to meet EO 13693 

(Planning for Federal Sustainability in the Next Decade-2015) objectives of energy efficiency and 

resiliency and “green design.” The number of historic federal buildings now being LEED 

certified by the U.S. Green Building Council continues to rise. GSA continues to be in the 

forefront of historic building resiliency.

Many federal agencies reported policies and procedures across real property management and 

planning departments specifically addressing the need to consider repurposing of existing 

facilities—both historic and non-historic. Agencies continue to ensure their operations 

and actions are carried out in an environmentally, economically, and fiscally sound manner. 

Incorporating sustainable practices into their missions conserves energy and natural resources, 

reduces pollution and contamination releases, enhances the workplace through less exposure to 

hazardous materials and chemicals, and strengthens national security by encouraging energy 

independence. Several agencies have been compiling data to evaluate the threats of rising sea 

levels, increased risk of fire, drought, and erosion, to include potential effects to archaeological 

and historic sites.

Responding to interest from 

the movie Hidden Figures, KSC 

hosted several events to honor 

the legacy of female and African 

American employees and their 

contributions to the U.S. Space 

Program. In December 2016, 

it hosted a panel discussion 

with the director, composer, 

and actors of the film. Several 

screenings of the film were 

open to the public. Additionally, 

in honor of Women’s History 

Month and African American 

History Month, presentations 

were given in 2017 by authors 

Wanda Harding, Richard Paul, 

and Steven Moss. 

From the left are: former CNN 

space correspondent John 

Zarrella; Ted Melfi, writer and 

director of Hidden Figures;

Actresses Octavia Spencer, Taraji 

P. Henson, Janelle Monáe; Pharrell 

Williams, musician and movie 

producer; and Bill Barry, NASA 

chief historian.
50 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

Highlights:

›› GSA’s Green Building Upgrade Information Lifecycle Database (gBUILD) on High 

Performance Green Building (HGPG) projects demonstrates clearly that historic 

buildings can meet very rigorous standards for improved performance and efficiency. 

GSA has found most of these actions taken have little or no adverse impact on significant 

historic spaces and features.

›› In 2015, Reclamation’s Lower Colorado Region was recognized by the U.S. 

Green Building Council with the LEED Gold Certification for integrating green, 

environmentally sustainable designs and energy efficient technological features into the 

major renovation of two historic buildings previously scheduled for demolition and 

located in and contributing to the Boulder City Historic District.

›› NASA mandates Centers to develop plans and strategies to incorporate technologies and 

best practices that will enable them to identify and execute the most cost-effective energy 

initiatives, which will improve NASA’s energy security and reduce the Agency’s total lifecycle costs in support of missions.

›› In 2017, CBP was awarded a joint award in the categories of Resilience Role Model 

and Historic Preservation for the successful modernization of programs and policies to 

anticipate, prepare for, and adapt to climate change impacts on operations and agency 

missions and outstanding achievement to further the goals of the NHPA. The project 

exemplified the successful collaboration between multiple offices and the Puerto Rico 

SHPO. The team worked to maintain the historical significance of the NRHP-listed 

Customs House, while meeting resiliency goals of protecting the building from rising 

waters, high winds, and other climate threats present in hurricane and flood zones, in 

addition to reducing energy consumption.

›› The Department of the Treasury takes advantage of inherent features in its historic 

buildings to maximize resiliency. Prime examples include large windows that support 

the use of natural lighting, high ceilings that allow greater air circulation, and a durable 

natural masonry exterior wall with a significant thermal mass to help regulate interior 

temperatures.

›› Through successful completion of project reports, contexts, and other deliverables from 

DoD’s Legacy Resource Management Program, DoD is better positioned to manage its 

cultural resources for Defense mission sustainment and resiliency. Legacy provides tools 

to better enable DoD to enhance cultural resources through proactive management, 

which enables military readiness. Project examples from the reporting period include 

“Implementing Environmental & Economic Cost-Benefits of Reusing DoD’s Pre-World 

War II Buildings,” Legacy project #14-735; “Works of a Master? Addressing Evaluation 

of Routine or Prosaic Architecture by Famous Architects on Military Facilities,” Legacy 

project #15-779; and “20th Century Building Materials and Suitable Substitutes For 

Exterior Finishes and Roofs,” Legacy project #15-707.

Using historic properties through leasing. 

For situations in which agencies may not have a current need for a historic property, but want 

to retain ownership of the property so it may be used to meet foreseeable needs, agencies 

lease the property to non-federal entities under Section 111 of the NHPA as a way to ensure 

their preservation. As time goes by, more agencies are exploring opportunities to outlease (as 

GSA refers to them) historic buildings and structures instead of outright disposing of them. 
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 51

Outleasing minimizes federal maintenance costs, generates federal revenue that can be used for 

preservation purposes, and preserves these historic facilities themselves. Agencies with often 

very specialized properties, like NASA or the Department of Energy, have found leasing a 

viable alternative to demolishing them. At the same time, the leasing of historic properties to 

house federal functions, where practicable, extends the lives of those properties and provides 

a cost and maintenance advantage to the government.

Of the agencies responding to the Section 3 request for data, the federal agency with the 

most experience in leasing and exchanging federal property is GSA. Its use of Section 111 

authority for leasing unneeded federal space to nonfederal entities, and finding space in 

non-federally owned historic properties, continues to make an important difference at historic 

buildings, especially in smaller markets, with buildings requiring only modest reinvestment 

to remain viable. 

Most outleases fill vacant space or provide retail services in buildings predominantly housing 

federal agencies. While some are long-term and entire buildings are outleased, others consist 

of discretely placed rooftop antennae and short-term event space rentals. Between 2015 and 

2017, GSA’s short-term event space outleasing program has grown; historic buildings served 

as locations for more than 25 movies and television shows filmed by 21production companies, 

including, among others: Alexander Hamilton U.S. Custom House, New York, New York 

(Billions, 2017, Showtime); U.S. Custom House, Baltimore, Maryland (House of Cards,

2013-present, Netflix Original Production); and, Federal Center, Chicago, Illinois (Batman vs. 

Superman: Dawn of Justice 2015, Warner Bros. Pictures). GSA’s national preservation program 

supports this stewardship funding source with online guidance, along with sample documents 

that include GSA’s standard license, permit application, special conditions and clauses for 

protection of historic finishes and fixtures. GSA regional preservation programs supplement 

this guidance with regionally focused training programs, manuals, brown bag events, and blogs 

that promote outleasing successes to GSA employees nationwide.

In accordance with the authority, GSA’s outlease revenue is reinvested exclusively in historic 

buildings through a rigorous and highly competitive process, in which projects are required to 

meet the Secretary of the Interior’s Standards. Combined with other funding sources, proceeds 

from Section 111 leases fill critical gaps and enable GSA to seize opportunities for meeting 

stewardship goals.

Highlights:

›› Nationwide: VA Secretary Shulkin approved use of the authority found in NHPA 

Section 111 to lease historic VA properties to external parties. The Office of Construction 

and Facilities Management is charged with implementing the program. A handbook 

detailing leasing procedures has been drafted, and initial solicitation for a pilot project in 

Sausalito, California, has been initiated. More than a dozen vacant cemetery lodges are 

also being considered for partnerships under this authority. At the same time, VA also 

continued to pursue multiple leases across the county, pursuant to its Enhanced Use-Lease 

(EUL) Program. The EUL Program allows VA to outlease its underutilized real estate to 

the private sector for up to 75 years for the purpose of developing supportive housing for 

homeless and at-risk veterans and their families. One such notable EUL currently under 

development, was the reuse of several NHL properties at the Clement J. Zablocki VA 

Medical Center in Milwaukee, Wisconsin, which will be rehabilitated for veterans’ housing 

using historic tax credits.
52 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

›› Massachusetts: GSA rehabilitated the 1836 New Bedford Custom House, the oldest 

continuously operating custom house in the nation, and now it houses both CBP and 

NOAA operations. The building lies in the New Bedford Whaling National Historical 

Park and contributes to the New Bedford National Historic Landmark District. Work 

initiated between 2015 and 2017 includes exterior repointing, marble floor repair, energy 

saving HVAC upgrades, thoughtfully integrated exterior accessibility, and minor interior 

changes to accommodate NOAA. GSA strategically reinvested outlease proceeds, 

combined with other funds, and the building is now fully occupied by federal agencies.

›› Florida: NASA has a lease agreement with SpaceX for use of the NRHP listed Launch 

Complex 39A Historic District at KSC. SpaceX has managed to maintain a majority 

of the historic structure while meeting the current technological/operational needs 

for launch. In the past few months they have used this pad for historic first launches, 

including the first-ever return of a rocket first stage.

›› Michigan: USACE’s Detroit District leases a building on the Soo Locks property for use 

as a maritime museum in the City of Sault Sainte Marie.

›› Washington, D.C.: GSA’s long-term lessor concluded a $200 million rehabilitation 

and adaptive use of the 1899 Old Post Office in Washington, D.C.’s Pennsylvania 

Avenue National Historic Site without any adverse effect to the historic building. The 

Romanesque Revival icon is now a hotel within pedestrian reach of museums, memorials, 

businesses, and government offices in Washington, D.C.’s monumental core. Revenue 

generated by the ground lease has already funded conservation of on-site art by Robert 

Irwin and the Benjamin Franklin statue on Pennsylvania Avenue. In 2017, the 315-foot 

bell tower reopened, offering panoramic views of the National Mall and landmarks of the 

nation’s capital. Operated by the NPS, access to the tower is free and open to the general 

public.

Meeting the requirements of the Federal Assets Sale and Transfer Act 

and the Federal Property Management Reform Act. 

Late in 2016, these two statutes were enacted that affect many real property-owning federal 

agencies. The Federal Property Management Reform Act (FPMR) tasks the FRPC with 

establishing a real property management template of measures, standards, milestones, etc. to 

reduce surplus federal property and achieve better utilization of underutilized property. Staff 

at GSA support the FRPC which issues the FRPP each year. Under the Federal Assets Sale 

and Transfer Act (FAST Act-Property), the yet-unfunded Public Buildings Reform Board is 

charged with identification of “high value assets” for disposal within a limited period of time. 

Both statues seek to advance the goals of earlier “Freeze the Footprint” and subsequent “Reduce 

the Footprint” White House policies. Federal agency “Reduce the Footprint” policies and 

procedures, and related legislation, address protection of historic properties, in various ways.

Of the federal agencies that responded to this question in the ACHP’s reporting guidance, 

BLM, Reclamation, TVA, USPS, and the USCG are exempted from one or both laws by 

name. Other responding agencies, like DHS, own some properties that are specifically 

exempted “for reasons of national security.” 

The ACHP also supports the concept that Reclamation noted in its Section 3 report, 

regarding consideration of historic property values and significance as early as possible in 

disposal decision making because not all historic properties “hold a value that warrants their 

retention in the face of the expressed requirements to reduce the federal property inventory.” 
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 53

NASA, GSA, AND PRIVATE 

INDUSTRY COLLABORATE 

TO REHABILITATE HISTORIC 

AIRFIELD

In 2015 GSA concluded commercial lease negotiations to rehabilitate and operate NASA’s 

1,100-acre historic Moffett Federal Airfield in California’s Silicon Valley. The 60-year public-private 

partnership between NASA’s Ames Research Center (ARC) and Planetary Ventures (a subsidiary 

of Google) will eliminate NASA’s management costs and rehabilitate the historic Hangar One for 

private business use while meeting the needs of the federal government and California National 

Air Guard to retain a limited use airfield. The lease area falls within the NRHP-listed Shenandoah 

Plaza Historic District. ARC is using proceeds from the lease to maintain and upgrade its historic 

properties. This is the first large-scale Section 111 lease NASA has executed, and it is serving as a 

model for future leases. (Note: NASA has previously entered into another Section 111 lease with 

Carnegie Mellon University to occupy Buildings 23 and 24 within the Shenandoah Plaza Historic 

District at Ames.)

Hangar I at Moffett Field 

2008 aerial view (color) of NASA research park, Moffett Airfield, 

CA showing Shenandoah Parade Grounds and Plaza 

1943 photo (black and white) of N. Moffett Field, east from front 

gate toward Shenandoah Plaza and Hangar One

(all photos courtesy NASA)

CASE

STUDY
54 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

To summarize the responses about impacts of the FAST Act-Property and the FPMR, it 

is too early to tell how compliance may yet affect the historic property holdings of federal 

agencies subject to their requirements. Large agencies with a solid inventory of their historic 

properties (like GSA or the USPS), and smaller agencies with few (NOAA, Treasury) or 

specialized historic properties (NASA, DHS) are in the best position to ensure that historic 

values are known prior to decisions about their future. Smaller agencies stated that their 

existing historic properties were fully utilized and they did not expect any changes in the 

foreseeable future. The Section 106 review process is the vehicle most agencies will use to 

ensure that a property’s historic significance has a place in making decisions about retention, 

reuse, excessing, or disposal.

Highlights:

›› GSA issued templates and guidance for landholding agencies to submit data and 

recommendations for real property disposal, consolidation, colocation, reconfiguration 

or redevelopment in support of the FAST Act-Property footprint reduction and sales 

revenue goals.

›› Department of Labor explicitly states these laws will not affect its historic properties or 

affect the mission.

›› NASA submitted its recommendations for consideration by the Public Buildings Reform 

Board in April 2017, identifying three facilities for potential disposal. NASA expects to 

coordinate with GSA for compliance with Section 106, as appropriate for the transfer of 

property out of federal ownership.

›› During this reporting period the ACHP published Guidance on Use of Real Property 

Restrictions or Conditions in the Section 106 Process to Avoid Adverse Effects (http://www.achp.

gov/preservationconditions.html). This guidance, with origins in the congressionally 

mandated ACHP report Preserving Historic Post Offices: A Report to Congress [http://www.

achp.gov/historicpostoffices.pdf ] is designed to assist federal agencies that are considering 

placing a covenant or Preservation Condition on properties they propose to transfer 

out of federal ownership. The use of a Preservation Condition to preserve historically 

significant characteristics of a property can lead to a finding of no adverse effect in the 

Section 106 review of the transfer. This guidance also educates preservation stakeholders 

on Preservation Conditions—what they are, who develops them, and their enforceability.

The ACHP strongly supports GSA’s statement in its Section 3 report that historic building viability 

is best accomplished through:

• reinvesting in them to continue to meet federal workplace needs; 

• reprogramming them to serve new uses as necessary;

• outleasing vacant or underutilized historic properties to non-federal tenants when there is no 

immediate federal need; 

• leasing historic buildings from non-federal building owners, when no federal space is available; 

• acquiring historic properties to meet federal needs, when acquisition is cost effective and 

prudent; 

• and creating disposal strategies to promote preservation-appropriate reuse of historic 

properties.
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 55

Federal agency progress reports and the interactions the ACHP has had with property 

managing agencies during this reporting period demonstrate that agencies are making 

important progress in identifying, protecting, and using historic properties. These reports and 

interactions also suggest that targeted assistance and adjustment to existing practice and policy 

would better position them to address current impediments and make further improvements 

to fully achieve the goals of this EO. 

Agencies are clearly taking steps to improve their management and the condition of historic 

properties under their stewardship. While some agencies continue to face challenges 

incorporating historic preservation into their broader mission, as noted in this report even 

these agencies continue to evidence a commitment to the stewardship of historic properties as 

they carry out their missions. The steps agencies take to identify, protect, and use their historic 

properties vary widely given the diverse range of historic property types and agency missions.

In general, these reports demonstrate that the federal historic preservation program works to 

the benefit of the American people and the agencies that manage it. Federal agencies and the 

ACHP are advancing the Administration’s agenda on infrastructure, and taken together, these 

broader efforts create jobs, stimulate tourism, and contribute to the economy. 

The recommendations provided below are clearly achievable in order to further advance the 

stewardship of historic properties and the goals of this Administration. The ACHP has 

identified the following findings, which are accompanied by recommendations on specific 

actions the ACHP and others can take to resolve them. 

FINDINGS AND 

RECOMMENDATIONS

CHAPTER 5

Civil War Cannons Recovered 

from the Pee Dee River near 

Florence, SC (photo courtesy 

Gerry Melendez, The State Media 

Company of South Carolina)
56 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

FINDING:

Agencies that have already used Section 106 program alternatives were able to 

improve the efficiency and cost effectiveness of project reviews. 

Title 41 of the Fixing America’s Surface Transportation Act has had and will continue to have 

a significant impact for federal agencies that manage property and approve major infrastructure 

projects that may cross or fall within these properties, such as pipelines, transmission lines, 

and communication facilities. Commitments by the Administration to advance energy 

development mean that more infrastructure projects will likely occur on federal land. In its 

oversight of the Section 106 review process, the ACHP can, and has, played an important 

role in advising on program improvements for infrastructure and informing federal policy on 

improving environmental reviews.

Customizing Section 106 reviews for complex infrastructure projects and programs can 

improve the efficiency, effectiveness, transparency, and predictability of these reviews. While 

some agencies have utilized such tailored alternatives for transportation and communication 

programs, few program alternatives have been established for pipeline and transmission 

projects and other major infrastructure sectors. 

Opportunities for the ACHP to collaborate with federal agencies on establishing program 

improvements and alternatives have been significantly enhanced by the ACHP’s membership 

on the Permitting Council.

Recommendations:

›› Agencies should strengthen and expand the use of Section 106 program alternatives to improve 

the efficiency and cost-effectiveness of project review for energy and infrastructure projects affecting 

historic properties on federal lands.

›› The Administration should continue to include the ACHP in policy level workgroups to identify ways 

to improve the effectiveness and efficiency of environmental reviews for infrastructure projects while 

promoting effective historic preservation outcomes.

›› The ACHP should continue outreach to industry, state and tribal officials, and other key stakeholders 

to identify and implement effective opportunities for improving Section 106 reviews for infrastructure 

projects.

›› Agencies should identify opportunities to improve coordination, collaboration, and support for the role 

of State and Tribal Historic Preservation Officers in Section 106 reviews on infrastructure projects.

FINDING:

Efforts to identify historic properties and ensure that consistent information about 

historic property inventory efforts are made available electronically can better inform 

and improve real property management and federal and non-federal planning.

As illustrated in Chapters 2 and 3, there are a multitude of property management databases 

within federal agencies and State and Tribal Historic Preservation Offices. While the 

FRPP was intended to be a single government-wide inventory and tracking system for the 

government’s real property, it has not been used as a stewardship tool and likely lacks the 

attributes to function as such. Neither federal building nor land managing agencies’ Section 3 

reports note a movement to its increased use as the mechanism to track sufficiently detailed 
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 57

information about its full inventory of historic properties and how they are being used and 

protected. Further, there is also no evidence in the reports that land managing agencies are 

actively seeking to adjust the FRPP to meet their needs. 

Following the Preserve America Summit in 2006 and in a variety of circumstances thereafter, 

the ACHP and other preservation organizations and stakeholders have urged federal and 

non-federal partners to support the development of a nationwide inventory that would include 

information about historic properties and past cultural resource surveys. Further investment 

in the development and completion of such a system would provide a significant return on 

investment in the form of providing accessible and consistent information to inform future 

project planning and development and, in doing so, assist applicants and federal agencies 

in better avoiding and managing impacts to historic properties in the future. The ACHP’s 

recommendations have urged the development of such a system within State and Tribal 

Historic Preservation Offices, which have already built substantial inventories of historic 

properties within their respective boundaries in part to comply with the requirements of 

the matching funding they receive through the Historic Preservation Fund. While many 

SHPOs and THPOs have made great strides in the development and management of their 

own systems, they lack a broad mandate, guidance, and predictable resources to ensure these 

systems meet national standards and remain electronically available. 

To meet the long-range goal of a more comprehensive inventory of the historic properties 

owned by the government, it will be critical that these various databases and tracking systems 

be able to communicate with each other, account for all kinds of historic properties using 

common metrics, and address rights of access, information content and ownership, and 

numerous other issues. 

Recommendations: 

›› NPS, DoD, GSA, and the ACHP, in consultation with NCSHPO and National Association of 

Tribal Historic Preservation Officers, should review currently available systems and take steps to 

promote the development of an electronically available inventory of previous surveys and the presence 

of historic properties that meets national inventory standards.

›› The ACHP should continue to work with federal agencies as part of the Federal Permitting 

Improvement Steering Council to identify more efficient and effective ways to share secure information 

about the location and significance of historic properties.

›› Agencies should strive to identify and commit regular funding to meet the requirements of this EO 

and Section 110 of the NHPA to complete their inventory of historic properties under their ownership 

or control. 

FINDING:

Partnerships can leverage limited federal resources and provide important benefits to 

federal agencies in the identification, protection, and use of historic properties. 

As set forth in Section 2 of the Preserve America EO, federal agencies should be encouraged to 

build and foster preservation partnerships consistent with agency missions. As has been made 

abundantly clear throughout this report, federal agencies rely on cooperative partnerships 

and relationships with the other federal agencies, states (and not just with SHPOs), Indian 

tribes, NHOs, and the private sector to achieve preservation objectives they otherwise could 

not meet by themselves. Generally speaking, federal agencies partner with other entities 

because they share or have adjacent cultural or natural resources; often are within the same 
58 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

larger department so share common regulations or policies; look to others for particular kinds 

of assistance, expertise, or knowledge; and have a common interest in protecting historic 

properties and telling their stories.

In their responses, many agencies spent considerable time describing their partnerships, how 

they assist the agency, and their accomplishments. They are rightly proud of their ability 

to bring their history to the wider public, and it shows in their reporting. However, some 

agencies responded that they do not have or pursue preservation partnerships due to security 

requirements or other impediments. The value of partnerships is clear, and the following 

recommendations on steps agencies can take to develop, expand, and better use partnerships to 

achieve the goals of this EO are provided below. 

Recommendations:

›› Agencies that do not employ partnerships should identify and work to remove any factors that might 

limit their ability to enter into partnerships to assist them in addressing historic preservation goals and 

requirements.

›› The ACHP should work with the NPS and the Administration to expand and foster the Preserve 

America Stewards Program and other agencies to identify volunteer programs which include work on 

the protection of historic properties.

FINDING:

Agencies would benefit from more effective mechanisms to ensure timely 

involvement of Indian tribes and NHOs in property management activities and 

infrastructure planning. 

The challenges regarding tribal involvement in infrastructure projects were the focus 

of an unprecedented interagency tribal consultation effort in late 2016; the subject of a 

roundtable discussion at the Senate Committee on Indian Affairs in September 2017; and, 

the longstanding work of the ACHP. There remains a strong interest in seeing improvements 

among all involved, notably tribal leaders, federal officials, and industry representatives. 

One outcome of the interagency consultation was a report issued by the ACHP, Improving 

Tribal Consultation and Tribal Coordination in Federal Infrastructure Decisions (May 2017) 

[http://www.achp.gov/docs/achp-infrastructure-report.pdf ] which provided a number 

of recommendations on improving tribal consultation for infrastructure projects. These 

recommendations included, among other things, that federal agencies involved in infrastructure 

projects should develop guidance and procedures to improve coordination between applicants 

and Indian tribes prior to the selection of preferred alternatives, plan for consultation with 

Indian tribes on a landscape and programmatic level, and develop procedures for ensuring that 

consultation begins as early as possible. 

In addition to the recommendations within this report, there are a number of other steps 

the ACHP and federal agencies that manage property can take to improve consultation 

with Indian tribes and NHOs regarding impacts to historic properties on federal lands and 

properties. 
 IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 59

Recommendations: 

›› Federal agencies should ensure all staff are aware of, and act in accordance with, government-wide 

and agency policies and directives regarding tribal and NHO consultation.

›› Federal agencies should ensure all appropriate staff receives training in environmental and cultural 

resource/historic preservation responsibilities as well as tribal and NHO consultation.

›› The ACHP should develop guidance regarding early coordination with Indian tribes and NHOs in 

Section 106 and pre-application processes and incorporate training regarding tribal involvement in 

infrastructure projects into its new training products.

›› The ACHP should work with NPS to further train and advise federal agencies on appropriate steps 

to identify, manage, and protect traditional cultural places of significance to Indian tribes and NHOs, 

including updates to existing NRHP Bulletins and guidance.

FINDING:

Further development of policies and procedures to assist federal agencies in 

considering historic properties as part of their efforts to comply with “Reduce the 

Footprint” requirements would improve preservation outcomes without delaying 

compliance with these requirements.

As discussed above, the Federal Assets Sale and Transfer Act and the Federal Property 

Management Reform Act present historic preservation challenges and opportunities. These 

two laws will have a significant impact on how the federal government will consider historic 

significance in its footprint reduction strategies and initiatives. 

While agencies generally are meeting the requirements of these acts, it is often challenging for 

them to factor historic preservation goals and values early in agency planning to reduce federal 

property holdings. Developing clearer policy and procedures on when and how to consider the 

historic preservation values of federal assets that may be historic would better inform decisions 

as to whether to dispose of such an asset and help ensure the protection of those historic 

properties that leave federal ownership. 

Recommendations: 

›› The ACHP should continue to work with the FRPC, GSA, and OMB to expand and improve the 

ACHP’s access to data within FRPP so it can continue to assist in refining data fields that provide 

information about federally owned historic properties and to use these data to measure trends and 

make recommendations on improving the management of federally owned historic properties. 

›› The ACHP should identify and work with all agencies with independent disposal authority, including 

GSA, to develop and publish guidance on best practices and program alternatives to help those 

agencies complete preservation compliance for such disposals.

›› The ACHP should expand and promote its Guidance on Use of Real Property Restrictions or 

Conditions in the Section 106 Process to Avoid Adverse Effects to assist federal agencies in 

developing more effective uses of preservation covenants to expedite the disposal of historic properties 

by avoiding adverse effects.

›› The ACHP should continue to work with the USPS to implement recommendations within the 

ACHP’s earlier report, Preserving Historic Post Offices: A Report to Congress and identify 

other areas where it can collaborate on improving current inventory and control mechanisms that 

assist USPS in managing its historic assets.
60 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018

FINDING:

Fostering and encouraging the reuse of historic facilities by federal agencies or others 

creates cost-effective preservation outcomes. 

In an effort to reduce their real estate footprint many agencies consolidate multiple offices 

into one central office. Others seek downtown or Main Street locations to serve growing 

urban populations. Centrally located, federally owned historic buildings help agencies meet 

consolidation needs, reducing real estate footprints and dependence on costly leased space 

from the private sector. They also contribute to the economy and vitality of downtowns and 

communities.

Challenges to reuse include such issues as agency preferences, agency requirements, and tenant 

improvement costs. Some agencies prefer to consolidate in new, larger buildings–which must 

be purchased, built, or leased–so they may achieve better space utilization rates or enjoy onsite parking. Other agencies simply are unable to achieve savings or space utilization goals in 

historic buildings, which may require significant or excessive refurbishment to meet safety and 

seismic codes and other standards. 

Recommendations:

›› The ACHP should convene an inter-agency workgroup to develop success stories and guidance on 

consolidation and inter-agency collaboration for co-location in federally owned historic buildings and 

preservation and training for relevant agency personnel.

›› The ACHP should work with GSA and the FRPC to explore opportunities to integrate information 

on “historical status” into FRPP property management tools (https://www.gsa.gov/policyregulations/policy/real-property-policy/asset-management/real-property-asset-management-tools)

›› The ACHP should survey property management agencies to identify obstacles to reusing or 

“outleasing” historic properties, and the inter-agency workgroup should develop recommendations for 

overcoming those obstacles.

CONCLUSION

The ACHP is committed to working with its federal and non-federal partners to realize the 

goals of this EO and to implement the recommendations provided within this report. While 

the ACHP can take action on many of these recommendations, it encourages those federal 

agencies who play the primary role in identifying, protecting, and using historic properties 

under federal ownership to support these improvements and collaborate with the ACHP and 

other preservation partners in fully implementing historic preservation goals. 

The ACHP’s efforts since the issuance of this EO in 2003 in assessing the progress agencies 

are making in meeting its goals and providing stewardship for historic properties under their 

control or management demonstrates that the protection of historic properties is vitally 

important to the federal government and the American people. In every reporting cycle, federal 

agencies clearly are making progress in integrating historic preservation into their operations. 

It also demonstrates that the outreach federal agencies do to gather public input and support 

is vitally important. The successes of these efforts lie in every corner of the United States and 

its territories, and help tell the story of America.
 IN A SPIRIT OF STEWARDSHIP: APPENDIX | 61

The Federal Real Property Profile, managed by the Federal Real Property Council, houses 

information about the nature, use, and extent of the federal government’s real property assets. 

It contains data on all executive branch agency real property assets within and outside the 

United States, including improvements on federal land, except when otherwise required for 

reasons of national security, in accordance with EO 13327. 

An analysis of FRPP information should clarify the status of many federal historic properties, 

and to this end the ACHP requested access to information from the FRPP. Such access was 

supported by the U.S. Government Accountability Office’s 2013 Report Improved Data Needed 

to Strategically Manage Historic Buildings, Address Multiple Challenges, which recommended the 

ACHP’s access to this information and underscored the value it may present to efforts to 

better understand the progress agencies are making in identifying, using, and protecting 

historic properties under their ownership and control. The ACHP’s access was also supported 

by FRPP staff, at GSA, and by the FRPC member agencies, which promptly responded to 

the ACHP’s request for data from FY14, FY15, and FY16. For security reasons, FRPP data 

must be requested directly from DoD; the ACHP did so, but DoD was not able to provide the 

requested information. DoD assets comprise about half of those in the FRPP.

In order to identify broad patterns and trends in managing historic assets, the ACHP analyzed 

six departments with inventories of greater than 10,000 real property assets: Departments 

of Agriculture, Energy, Homeland Security, Interior, Transportation, and Veterans Affairs. 

These departments represent a combined average of approximately 256,000 records per year, 

or 85 percent of the average 310,000 records provided per year. The following preliminary 

conclusions are based on ACHP staff analysis of available data:

PRELIMINARY PATTERNS AND 

TRENDS IN ANALYSIS OF FRPP 

DATA ON HISTORIC PROPERTIES

APPENDIX 1

Eastern New Mexico University 

archaeology Field School, 

southeastern New Mexico 

(photo courtesy BLM)
62 | IN A SPIRIT OF STEWARDSHIP: APPENDIX

IDENTIFICATION OF HISTORIC PROPERTIES

›› Historic properties (National Historic Landmarks, NRHP eligible, and NRHP listed 

assets) comprise less than 10 percent of the federal asset inventory and generally are 

meeting agency mission needs.

›› During the reporting period, the number of assets agencies have reported as historic 

(NHL, NRHP-eligible, and NRHP-listed) has increased, from 15 percent in FY14, to 

28 percent in FY15, and to 40 percent in FY16. Since FY14 was the first year in which 

agencies were required to report historical status, and “not evaluated” is the default input 

in this field, the ACHP believes that most of these newly input historic properties 

represent improved record-keeping, with a small portion resulting from actual NRHP 

evaluation efforts within each fiscal year.

PROTECTION OF HISTORIC PROPERTIES

›› Each year, approximately 500 historic assets are considered as “unutilized,” which may 

mean they are at risk for adverse effects caused by lack of use, deferred maintenance, or 

potential disposal out of the federal inventory without adequate preservation conditions in 

place.

›› Further, each year the “status indicator” for approximately 300 federal historic assets notes 

that they are classified for disposal, excess, or surplus, which may mean they are at risk for 

adverse effects caused by lack of use, deferred maintenance, or potential disposal out of the 

federal inventory without adequate preservation conditions in place.

›› The data also indicate that agencies disposed of assets for which the Historical Status is 

“Not Evaluated.” 

Reinstallation of a New Deal 

Mural, Loop Post Office, Federal 

Center, Chicago, IL (photo 

courtesy Caroline Sachay/GSA)
 IN A SPIRIT OF STEWARDSHIP: APPENDIX | 63

USE OF HISTORIC PROPERTIES

›› The “condition index” for the average federal historic building or structure is equal or 

better than the average non-historic building or structure. (A condition index is not 

assigned to a land asset.)

›› Federal historic properties are only considered as slightly more “underutilized” than nonhistoric federal properties. 

The ACHP is pleased to have the opportunity to supplement this report with information 

from the FRPP, for the first time, and looks forward to continuing to work with FRPP staff 

and FRPC member agencies. In future triennial reports, the ACHP will request data to 

supplement the above analyses, to identify patterns and trends, to measure progress in meeting 

the goals of this EO, and to consider new questions that may arise. 

Note: Terms in quotes are defined in the FRPP 2017 Data Dictionary (https://www.gsa.gov/

policy-regulations/policy/real-property-policy/asset-management/federal-real-propertycouncil-frpc/frpc-guidance-library). 

Mission Operations Control Room, Johnson Space Center 

Houston 1969 (photo courtesy NASA)
64 | IN A SPIRIT OF STEWARDSHIP: APPENDIX

LIST OF AGENCIES REPORTING

AGENCY SECTION 3 REPORTS SUBMITTED, 2004-2017

Executive Branch Department/Agency 2004 

base 2005 2008 2011 2014 2017 #

Armed Forces Retirement Home (AFRH) Y Y Y Y 1

Agriculture, Department of (USDA) Y

Agricultural Research Service (ARS) Y Y Y Y

Forest Service (FS) Y Y

Farm Services Agency (FSA) (Y) Y Y *

Natural Resources Conservation Service (NRCS) Y Y * *

Rural Development (RD)

Commerce, Department of (DOC) Y Y

National Oceanic and Atmospheric Administration (NOAA) Y ◊ ◊ ◊ Y 2

National Institute of Standards and Technology *(NIST) Y 3

Defense, Department of (DOD) Y Y Y (Y) 4

United States Army Corps of Engineers (COE) Y Y (Y) 5

Education, Department of (DOE) * * * *

Energy, Department of (DOE) Y Y Y

Environmental Protection Agency (EPA) Y Y Y Y Y Y 6

Federal Energy Regulatory Commission (FERC) Y Y

General Services Administration (GSA) Y Y Y Y Y Y 7

Health and Human Services, Department of (HHS) Y Y Y Y Y

Homeland Security, Department of (DHS) Y Y Y Y Y Y 8

Federal Law Enforcement Training Center Y ◊ ◊ ◊

APPENDIX 2

Latte Stones in Guam © Rodrigo Roy Boncato – Fotolia
 IN A SPIRIT OF STEWARDSHIP: APPENDIX | 65

Housing and Urban Development, Department of (HUD) Y

Interior, Department of the (DOI)

Bureau of Indian Affairs (BIA) Y Y Y Y Y

Bureau of Land Management (BLM) Y Y Y Y (Y) Y 9

Bureau of Reclamation (Reclamation) Y Y Y Y Y 10

Fish and Wildlife Service (FWS) Y Y Y Y Y Y 11

National Park Service (NPS) Y Y Y Y Y (Y) 12

U.S. Geological Survey (USGS) Y Y (Y) Y Y 13

International Boundary and Water Commission (IBWC) Y 14

Justice, Department of (DOJ) Y Y Y (Y)

Federal Bureau of Prisons (BOP) Y Y ◊ ◊ Y Y 15

Labor, Department of (DOL) Y Y Y Y Y 16

National Aeronautics and Space Administration (NASA) Y Y Y Y Y Y 17

National Archives and Records Administration (NARA) Y Y

State, Department of (DOS) Y

Surface Transportation Board (STB) Y

Tennessee Valley Authority (TVA) Y Y Y Y 18

Transportation, Department of (DOT) Y Y Y Y Y

Federal Aviation Administration (FAA) Y ◊ ◊ ◊ ◊ Y 19

Federal Highway Administration (FHWA) * * * *

Federal Motor Carrier Safety Administration (FMCSA) * * * * *

Federal Railroad Administration (FRA) Y Y Y Y Y

Maritime Administration (MARAD) Y Y Y Y 20

Treasury, Department of (TREAS) Y Y Y Y Y 21

Bureau of Engraving and Printing (BEP) Y Y

U.S. Postal Service (USPS) Y Y Y (Y) Y Y 22

Veterans Affairs, Department of (VA) Y Y Y (Y) (Y) (Y) 23

Y = Report filed by deadline September 30.

(Y) = Draft or final report filed by publication of Report to President.

* = Agency notified the ACHP that the provisions of Section 3 of EO 13287 did not apply to them because they did not own real property.

◊ = Agency notified the ACHP that they will no longer file individual agency progress reports, but their information will be included in their parent 

 department/agency progress report.

Executive Branch Department/Agency 2004 

base 2005 2008 2011 2014 2017 #
66 | IN A SPIRIT OF STEWARDSHIP: APPENDIX

AGENCY SECTION 3 REPORTS SUBMITTED, 2004-2017

http://www.achp.gov/section3/

http://www.achp.gov/section3reports/reportindex.html

THIS REPORT TO THE PRESIDENT WAS BROUGHT TO YOU BY

Tom McCulloch, Ph.D., R.P.A. | principal author, assisted by

Katry Harris

Katharine Kerr

Kirsten Brinker Kulis

Blythe Semmer

Shayla Shrieves

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

John M. Fowler | Executive Director

Members of the Advisory Council on Historic Preservation

LINKS TO AGENCY SUBMISSIONS

AND ACKNOWLEDGEMENTS

APPENDIX 3

Milton-Madison Bridge, Kentucky and Indiana (photo courtesy Indiana Department of 

Natural Resources, Division of Historic Preservation & Archaeology)

Opposite: U.S. Courthouse, Erie, PA, subject of a Learning from Our Legacy case study 

(photo courtesy Carol M. Highsmith Photography, Inc./GSA)

2018

IN A SPIRIT

STEWARDSHIP of

A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT

Top: The Elbert P. Tuttle U.S. Court of Appeals Building in Atlanta, GA (photo courtesy Carol M. Highsmith Photography, Inc./GSA). 

Center L-R: Earth Day restoration of the Loko Paaiau fishpond, at Pearl Harbor, Oahu, HI (photo courtesy U.S. Navy). Graffiti 

removal at Painted Bluff, Marshall County, AL (photo courtesy TVA). Gavins Point Dam - Tail-waters below Gavins Point Dam on the 

Missouri River in South Dakota (Shutterstock). Skyline at Bridge of Lions, St. Augustine, FL (SeanPavonePhoto Fotolia)

Advisory Council on Historic Preservation

401 F Street NW, Suite 308

Washington, D.C. 20001-2637

Phone: 202-517-0200

www.achp.gov

www.preserveamerica.gov

Twitter and Instagram: @usachp

Facebook: Preservation-The Next Generation

 Preservation Indigenous-Native Youth

 ACHP-Advisory Council on Historic Preservation