FEDERAL STEWARDSHIP AND 

A M E R I C A’S HISTORIC LEGACY

A D V I S O RY COUNCIL ON

HISTORIC PRESERVAT I O N

MARCH 2001

C A R I N G F O R T H E P A S T M A N A G I N G F O R T H E F U T U R E
THE ADVISORY COUNCIL ON HISTORIC PRESERVATION IS AN I NDEPENDENT FEDERAL AGENCY ESTABLISHED

BY THE NATIONAL HISTORIC PRESERVATION ACT OF 1966, AS AMENDED (16 U.S.C. 470f). THE COUNCIL ADVISES

THE PRESIDENT AND CONGRESS ON HISTORIC PRESERVATION MATTERS, ADMINISTERS THE PUBLIC REVIEW

AND CONSULTATION PROCESS FOR FEDERAL UNDERTAKINGS ESTABLISHED BY SECTION 106 OF NHPA, 

AND WORKS TO IMPROVE FEDERAL POLICIES, PROGRAMS, PLANNING, AND DECISIONS WHEN THEY AFFECT

THE NATION’S HISTORIC AND CULTURAL RESOURCES. 

FOR MORE INFORMATION, CONTACT THE ADVISORY COUNCIL ON HISTORIC PRESERVATION, 1100 PENNSYLVANIA AVE. NW,

SUITE 809, WASHINGTON, DC 20004. PHONE: (202) 606-8503. WEB SITE: WWW.ACHP.GOV.
FEDERAL STEWARD SHIP A ND 

A M E R I C A’S HISTORIC LEGACY

A D V I S O RY COUNCIL ON

HISTORIC PRESERVAT I O N

MARCH 2001

C A R I N G F O R T H E P A S T M A N A G I N G F O R T H E F U T U R E
A D V I S O R Y C O U N C I L O N H I S T O R I C P R E S E R V A i i T I O N

“[T]he spirit and direction of the Nation are founded upon and reflected in its 

historic heritage, [and] the historical and cultural foundations of the Nation should 

be preserved as a living part of our community life and development in order to 

give a sense of orientation to the American people.”

–National Historic Preservation Act of 1966
C A R I N G F O R T H E P A S T i i i M A N A G I N G F O R T H E F U T U R E

P R E FA C E

During the last two years, the Advisory Council on

Historic Pre s e rvation has been studying how the

Federal Government could do a better job of preserving

the historic resources that it controls, and how it could

implement sound policies for their stewardship as we

enter the next century. This special report presents the

results of this study.

The Council met with key Federal officials from many of

the Federal agencies with stewardship responsibilities for

historic re s o u rces as well as other interested parties, held

onsite meetings at Federal facilities and management

a reas, and solicited views and ideas from a variety of individuals ranging from agency heads to private citizens.

The agency conducted re s e a rch and assembled suggestions on how the Federal Government could meet its

s t e w a rdship responsibilities for America’s cultural heritage more eff e c t i v e l y, while acting as a more eff e c t i v e

l e a d e r, manager, and partner with State, tribal, and local

g o v e rnments and the private sector in this endeavor.

The Council’s study reviewed many examples of Federal

historic pre s e rvation stewardship, both positive and negative. It concluded that improvements could be made in

t h ree major areas: leadership in building a historic

re s o u rce stewardship ethic; commitment for taking care

of the Nation’s historic public assets; and accountability

for making decisions that are in the public interest. A

f o u rth area, collaboration, was found to be an import a n t

means for achieving these and related objectives.

As the new century opens, it is vital that Americans learn 

to appreciate and take better care of our rich heritage.

The protection and enhancement of the Nation’s patrimony must be viewed as a continuing national priority,

and the Federal Government must demonstrate its leadership and commitment to effective public stewardship of

A m e r i c a ’s past. 

The Council believes that the Federal Government must

a s s e rt its role as first among equals in the care of public

p ro p e rt y. In the process, Federal agencies can develop

and sustain creative, cost-effective solutions to managing

the re s o u rces that are part of the Nation’s heritage.

C reating these solutions is not only in the national public interest, but is the right thing to do for ourselves and

for generations to come.
A D V I S O R Y C O U N C I L O N H I S T O R I C P R E S E R V A i v T I O N

C O U N C I L M E M B E R S

as of March 1, 2001

Cathryn Buford Slater, Chairman

Stephen B. Hand, Vice Chairman

James K. Huhta, Ph.D.

Arva M.P. McCabe 

Bruce D. Judd, FAIA

Carolyn J. Brackett

Parker Westbrook

Katherine A. Slick

Raynard C. Soon

Hon. Angus S. King, Jr., Governor of Maine

Hon. Floyd Adams, Jr., Mayor of Savannah, Georgia

Architect of the Capitol

Secretary of Agriculture

Secretary of Housing and Urban Development

Secretary of the Interior

Secretary of Transportation

Environmental Protection Agency

General Services Administration

Chairman, National Trust for Historic Preservation

President, National Conference of State 

Historic Preservation Officers

Observers: Secretary of Defense; National Association 

of Tribal Historic Preservation Officers

John M. Fowler, Executive Director
The Council wishes to thank those members of the public who contributed opinions, ideas, and suggestions to the 

electronic forum on the Council’s Web site. 

The Council also wishes to extend its appreciation and thanks to the many agencies, organizational units, and agency

personnel who assisted with information and suggestions for this report. The Department of Energy, the Bureau of

Land Management, the U.S. Forest Service, the General Services Administration, and the Department of the Army

were especially helpful and supportive throughout the conduct of this study. The National Park Service, the

Department of the Navy, the U.S. Coast Guard, and Maine State Historic Preservation Officer Earl Shettleworth, Jr.,

offered their hospitality and expertise to site visits at Great Smoky Mountains National Park, Pearl Harbor Naval

Base, and Portland and Augusta, Maine, respectively.

Special mention should be made of the late Gary Bauer, Associate Director of the BLM Arizona State office, whose

personal interest and involvement in the Phoenix meeting of the Council and support for BLM’s heritage programs

are gratefully acknowledged.

We also thank the following individuals and organizations for their contributions:

Task Force on the Millennium Initiative: 

James K. Huhta, Ph.D., Chair

Bruce D. Judd, FAIA

Arva M.P. McCabe

Richard E. Sanderson, Environmental 

Protection Agency

Michael Kaczor, USDA Forest Service

Peter Brink, National Trust for Historic Preservation

Kathryn Higgins, National Trust 

for Historic Preservation

Special thanks to Council members and observers for

their assistance in hosting meetings:

Assistant Secretary Mahlon “Sandy” Apgar,

Department of the Army 

Robert Peck, Public Buildings Commissioner,

General Services Administration 

Ray Soon, Chairman, Hawaiian 

Homelands Commission 

Earl Shettleworth, Maine State Historic 

Preservation Officer

Katharine Stevenson, Associate Director,

National Park Service 

For arranging or providing onsite testimony, hosting

meetings, and offering specific ideas and suggestions

that assisted in the development and preparation of

this report, we wish to thank:

Caroline Alderson, General Services Administration

Don Barger, National Parks Conservation Association

Tom Brown, National Park Service

Alan Downer, National Association of Tribal 

Historic Preservation Officers/Navajo Nation

Raymond Fatz, Department of the Army

Caroline Fisher, Department of the Army

Phil Francis, National Park Service

Jim Garrison, Arizona State Historic 

Preservation Officer 

J. Bennett Graham, Tennessee Valley Authority

David Guldenzopf, Department of the Army 

Rebecca Hommon, Department of the Navy

Cindy Kelly, Department of Energy

Keith Kintigh, Society for American Archeology

Roger K. Lewis, FAIA

Ellen Lovell, White House Millennium Council

Roger Meade, Department of Energy

Ray Moore, Department of Energy

Nathan Napoka, Hawaii State Historic 

Preservation Office

Keoni Nunes (Native Hawaiian)

Barbara Pahl, National Trust for Historic Preservation

A C K N O W L E D G M E N T S

C A R I N G F O R T H E P A S T v M A N A G I N G F O R T H E F U T U R E
A D V I S O R Y C O U N C I L O N H I S T O R I C P R E S E R V A v i T I O N

A C K N O W L E D G M E N T S

Gregory Paxton, Georgia Trust for 

Historic Preservation

Judith Propper, USDA Forest Service

David Scott, Historic Hawaii Foundation

Hannah Springer, Office of Hawaiian Affairs

Pete Toya, Pueblo of Jemez

Vincent Anthony Toya, Pueblo of Jemez

Richard Tune, Tennessee State Historic

Preservation Office

William Whatley, Pueblo of Jemez

Gary Wright, Department of the Army

For providing information, suggestions, and other

materials in meetings of Federal and State Historic

Preservation Officers, in interviews, in written 

materials, or during onsite visits, we wish to thank:

David Banks, National Park Service

Sarah Bridges, Natural Resources 

Conservation Service

James Bruseth, Texas State Historic 

Preservation Office

Evan DeBloois, USDA Forest Service

John Douglas, Bureau of Land Management

Susan Escherich, National Park Service

Pat Ezell, Tennessee Valley Authority

Laura Feller, National Park Service

Edward Friedman, Bureau of Reclamation

Michael Kaczor, USDA Forest Service

John Keck, Wyoming State Historic 

Preservation Officer

Kevin Kilcullen, US Fish and Wildlife Service

Greg Knott, National Trust for Historic Preservation

Trudy Kortes, National Aeronautics and 

Space Administration

Tom Lincoln, Bureau of Reclamation

Frank McManamon, National Park Service 

Wilson Martin, Utah State Historic 

Preservation Office

H. Bryan Mitchell, National Park Service

Marilyn Nickels, Bureau of Land Management

F. Lawerence Oaks, Texas State Historic 

Preservation Officer

Danny Olinger, Tennessee Valley Authority

Jill Osborne, USDA Forest Service

Tamar Osterman, National Trust for 

Historic Preservation

John Parascandola, Department of Health 

and Human Services

Constance Ramirez, General Services 

Administration/National Park Service

David Reese, U.S. Coast Guard

Paul Rubenstein, U.S. Army Corps of Engineers

Rebecca Shiffer, National Park Service

James Slager, Department of State

Donald Sutherland, Bureau of Indian Affairs

Jay Thomas, Department of the Navy

Karen Ronne Tupek, Department of Veterans Affairs

Richard Waldbauer, National Park Service

Scott Waldman, Department of Health 

and Human Services

Nancy Witherell, National Capital 

Planning Commission

For providing materials, sharing experiences and

ideas, writing or editing sections of the report, and

making other significant contributions, thanks are due

to Advisory Council on Historic Preservation staff:

Ron Anzalone (staff project director and 

principal report author)

David Berwick

Martha Catlin

Sharon Conway

Jane Crisler

Ralston Cox

Charlotte Fesko

John Fowler

Carol Gleichman

Valerie Hauser

Thomas McCulloch

Elizabeth Moss

MaryAnn Naber

Marjorie Nowick

Druscilla Null

Alan Stanfill

Stephanie Woronowicz
T A B L E O F C O N T E N T S

Preface......................................................................................................................................................................iii

Council Members ....................................................................................................................................................iv

Acknowledgments ....................................................................................................................................................v

Chapter 1. America’s Challenge ............................................................................................................................1

A Call to Action ................................................................................................................................................1

Figure 1–Terminology ..................................................................................................................................2

About this Report ..............................................................................................................................................5

Chapter 2. Federal Stewardship of America’s Heritage–A Context....................................................................6

How Did the Federal Government Get into the Preservation Business?..............................................................6

Federally Owned or Managed Historic Resources..............................................................................................7

Federal Stewardship Mandates ..........................................................................................................................8

Figure 2–National Historic Preservation Policy ..........................................................................................9

Figure 3–Federal Agency Historic Preservation Programs Under Section 110............................................10

Historic Preservation Policies and Programs ....................................................................................................11

Figure 4–Principal Federal Agency Property Managers–Historic Resource Holdings ................................12

Figure 5–Comparison of Federal Property Managing Agency Historic Preservation Programs..................14

How Well Has the Federal Government Been Doing? ......................................................................................15

Conclusion........................................................................................................................................................19

Chapter 3. Challenges of Federal Stewardship–Themes and Variations ........................................................20

The Government’s Landlord and Public Buildings............................................................................................20

Science, Technology, and Research Laboratories ..............................................................................................24

The Nation’s Defense and Related Institutions ................................................................................................28

Figure 6–Special and Desirable Resources: Lighthouses and Lodges..........................................................33

Public Lands and Multiple Uses........................................................................................................................36

Parks, Refuges, and Sanctuaries........................................................................................................................42

Public Works and Infrastructure ......................................................................................................................48

Areas of Interest to Native Americans ..............................................................................................................50

Conclusion........................................................................................................................................................54

Chapter 4. Historic Resource Care and Management–Summary of Findings ................................................55

Figure 7–Major Federal Stewardship Responsibilities: Did You Know. . . ? ..............................................60

C A R I N G F O R T H E P A S T v i i M A N A G I N G F O R T H E F U T U R E
A D V I S O R Y C O U N C I L O N H I S T O R I C P R E S E R V A v i i i T I O N

T A B L E O F C O N T E N T S

Chapter 5. Successful Stewardship of the Past–Needs and Recommendations for Improvement..............61

Leadership: Building a Historic Resource Stewardship Ethic............................................................................61

Leadership Needs ......................................................................................................................................61

Recommendations......................................................................................................................................63

Commitment: Taking Care of the Nation’s Historic Public Assets....................................................................65

Commitment Needs....................................................................................................................................65

Recommendations......................................................................................................................................69

Accountability: Making Preservation Decisions in the Public Interest ..............................................................70

Accountability Needs ................................................................................................................................70

Recommendations......................................................................................................................................72

Collaboration: Finding and Working with Partners..........................................................................................73

Collaboration Needs ..................................................................................................................................73

Recommendations......................................................................................................................................75

Council Commitments......................................................................................................................................76

Afterword ........................................................................................................................................................76

Research Sources and Bibliography ........................................................................................................................77

Appendix 1. Policy and Program Recommendations Provided to Specific

Agencies as Part of this Study ..........................................................................................................................81

Appendix 2. Policy, Budget, and Strategic Planning Initiatives Related to

Historic Resources Stewardship Begun by Agencies During the Course of this Study......................................85

Appendix 3. Other Recent Initiatives: America’s Treasures, Legacy, and “My History” ........................................86

Notes on this Study ................................................................................................................................................87
C H A P T E R 1

A M E R I C A ’ S C H A L L E N G E

A CALL TO ACTION

The occasion of the Millennium gives citizens an

unprecedented opportunity to celebrate and protect

their heritage. Many, perhaps most, Americans see the

benefits of a beautiful, vast, culturally rich, and diverse

Nation, with tremendous resources in both public and

private hands that are linked to the Nation’s past and

provide opportunities for its future. 

The number of Americans who want to live, work, and

play in distinctive places with a patina of time is gro w i n g .

These citizens depend on cultural heritage and traditions

to re i n f o rce values and their own sense of worth. Many

of them want to reside and participate in communities

that make the most of their heritage, pre s e rve its best

reminders, and use older homes, commercial districts,

and noted landmarks to establish their community identity and increase its livability as well as its economic vitali t y. They want to take their families to visit historic sites,

feel the presence of those who came before, and learn

f rom the past. To d a y, more and more citizens see history

and historic re s o u rces as a part of an environment that is

w o rth pre s e rving, cherishing, and using to enrich their

lives and those of their children and grandchildre n .

Over the last 40 years, historic preservation has also

become a more routine and accepted part of local and

regional planning, community development, and business enterprise, and there are many success stories to

tell. Today it is instructive and encouraging to see how

far we have come in preserving our heritage. However,

it is also daunting to see how far we still need to go to

preserve our past and its reminders in many regions

and communities throughout the country.

Though a great deal of historic pre s e rvation eff o rt has been

and continues to be locally and privately driven by grassroots eff o rts, the Federal Government remains a key player

and facilitator in this arena. The Federal Government can

play a significant role in protecting our cultural heritage in

t h ree basic ways. First, it can foster public appreciation of

the values associated with the country ’s history, and back

such promotion with sound programs and other assistance.

Second, it can be sensitive and responsive to other public

and private pre s e rvation eff o rts, and avoid actions that are

in conflict with those objectives. Third, and perhaps most

i m p o rtant, the Federal Government can take better care of

the historic re s o u rces it holds in trust for the American people. America’s leaders need to consider governmental priorities at all levels, and determine how stewardship of the

N a t i o n ’s cultural heritage fits in their agenda. 

The Federal Government manages a large percentage of

A m e r i c a ’s historic assets (see Figure 1, page 2), f rom the

national parks, forests, and museums that it operates, to

the less obvious but no less important pro p e rty holdings

used to carry on the business of Government in off i c e

buildings, military installations, re c reation areas, and

re s e a rch laboratories. These re s o u rces comprise a substantial part of the Nation’s cultural patrimony. Federal stewa rdship and leadership can encourage others and set a stand a rd of excellence for them to emulate, while off e r i n g

o p p o rtunities for creative partnership to protect America’s

heritage. A serious commitment needs to be made to do so. 

In the face of prosperity and accompanying change, the

past and its reminders take on new meaning and importance. While there are thriving historic downtowns, wellp re s e rved residential districts, and well-maintained local

landmarks, some of our best historic assets—many of

them publicly owned—are neglected and virt u a l l y

unknown. Many popular public places—spectacular

national parks as well as other locations—are overu s e d

and under-maintained. Older public works and infras t ru c t u re, much of it historic, is in need of re p a i r. Much

of our prehistoric past, and our ability to understand

how things have come to be—is gone fore v e r, and more

is being lost each day. Entire ways of life in some re g i o n s ,

including ranching, farming, and Native American cultural practices, are disappearing, and often the public

lands retain their only physical reminders. 

If we do not take steps to preserve more of this historic

legacy under Federal Government control, what do we

stand to lose, and what opportunities are we missing? 

Enhancing the Quality of Life

Much has been made of pre s e rvation of historic 

communities, neighborhoods, landscapes, and ambiance

C A R I N G F O R T H E P A S T 1 M A N A G I N G F O R T H E F U T U R E
A M E R I C A ’ S C H A L L E N G E

TERMINOLOGY

Several diff e rent terms are typically used to discuss the tangible re s o u rces that are subject to historic and

cultural pre s e rvation laws and policies, and we must clarify their usage. 

Historic re s o u rc e s or historic pro p e rt i e s a re defined in the National Historic Pre s e rvation Act as “any 

p rehistoric or historic district, site, building, stru c t u re, or object included in, or eligible for inclusion in

the National Register of Historic Places, including artifacts, re c o rds, and material remains related to such

a pro p e rty or re s o u rce.” In current historic pre s e rvation policy and practice, such re s o u rces are usually

places, or objects with ties to specific places. 

The National Register recognizes pro p e rties significant in American history, arc h i t e c t u re, arc h e o l o g y, 

engineering, and culture, at the national, State, and local levels of significance. National Historic

Landmarks are National Register-listed re s o u rces that have been designated by the Secre t a ry of the

Interior as outstanding re s o u rces of national significance.

Heritage assets or heritage resources, in this context, are used by some Federal agencies as umbrella terms

that include historic resources. Used most often in a broader context, these are generally understood to be

publicly held resources with historic, natural, or cultural significance and value. Reporting on “heritage asset

holdings” is required of Federal agencies for financial accountability purposes under the Chief Financial

Officers Act and related laws. Often these assets have economic value, and may or may not have functions

or uses that meet current Federal agency mission needs and Government operations requirements. When

used in this report, the term “heritage assets” will generally refer to assets with historic significance.

Cultural resources are generally defined by Federal agencies to mean the same thing as historic resources,

although there is no consistent legal definition and individual agencies and organizations use different

emphases. Under 10 U.S.C. 2684, which deals with the Department of Defense’s responsibilities to manage

“cultural resources,” such resources are defined to include properties included in or eligible for inclusion in

the National Register of Historic Places; cultural items defined by the Native American Graves Protection

and Repatriation Act; archeological resources as defined by the Archeological Resources Protection Act; and

archeological artifact collections and associated records. The National Park Service lists archeological

resources, cultural landscapes, structures, museum objects, and ethnographic resources in its management

guidance and definition of “cultural resources.” Use of the term “cultural resources” by other agencies may

be confusing because arts agencies and cultural endowments may use it to refer to art, performance, music,

and other forms of cultural expression.

This report will use the term historic resources as the covering term to embody these various concepts.

F I G U R E 1

A D V I S O R Y C O U N C I L O N H I S T O R I C P R E S E R V A 2 T I O N
C A R I N G F O R T H E P A S T 3 M A N A G I N G F O R T H E F U T U R E

A M E R I C A ’ S C H A L L E N G E

in helping to pre s e rve the quality of life. Our personal,

e v e ryday lives are enriched by “user friendly” enviro nments that pre s e rve diversity, identity, green space, and

c h a r a c t e r. In revitalized communities, health and personal safety are increased, and more attention is paid to

basic infrastru c t u re, schools, and other key ingre d i e n t s

that may be linked to civic pride. 

Communities with easily identifiable public landmarks

offer a sense of place and well-being that is hard to find

in modern sprawl and mile-after-mile of roadside development. Key publicly owned historic resources, including post offices, courthouses, parks, and other Federal

assets, can provide an important nexus for other

preservation activities, and their loss can have negative

effects on the urban environment. 

Federal assets of all kinds—National Parks, National

F o rests, military installations, and other holdings—

c e rtainly play a role in the local and regional economic

p i c t u re as well as in its social stru c t u re. Heritage is good

for business generally, and it has certainly proven to be

good for tourism. Incre a s i n g l y, heritage or cultural

tourism makes up much of the economy of communities

and regions. Recent studies have found that 46 perc e n t

of U.S. adult travelers included a cultural, arts, heritage,

or historic activity while on a round trip of 100 miles or

m o re. Visiting a historic site such as a historic communit y, park, or building was the most popular activity

among travelers, amounting to an estimated 31 perc e n t

(62.6 million) of all travelers annually.1

Preserving Diversity

To d a y, regional and local distinction and uniqueness are

disappearing or becoming homogenized. America has often

been re f e rred to as a “Nation of Nations.” As such, it needs

to find a way for its unique blend of individuals, culture s ,

traditions, ethnic groups, and communities to thrive, while

not ignoring the heritage common to the entire country.

Ritual, belief, and perpetuation of traditional cultural practices may be singular and significant. So too may be the special places and landscapes associated with them. Many of

these places are on Federal and other public lands.

Ethnic groups and communities, particularly Indian

tribes, Native Hawaiians, and Alaska natives, value the

preservation of particular landforms, environments, or

other “natural” features imbued with cultural meaning,

as they are keyed to important practices and beliefs

integral to the survival of their culture. These heritage

values need to be respected and considered in how we

value the past. The Federal Government has a trust

responsibility to Native Americans, and needs to give

special attention to the care of these resources under its

jurisdiction and control.

Establishing Identity and Connections

All of us are connected to the past by a desire to know

who we are and where we fit in the modern world.

While our “roots” include our personal origins and

ancestral ties, it also includes our community or group

identity. We desire to learn about our family history

and the role it played in the broader currents of

American history, and we love to share some good family stories about our ancestors. As these stories are told

and passed on to younger generations, they become

part of our own story, and they can lend familiarity,

humanity, and reality to our relationship with the past. 

As Americans, we may also identify with the stories

and places of people from the past who are not directly related to us. The history of the rich, the powerful,

and the elite was often recorded; this was not true of

the broader population until the Civil War popularized

the use of photography of common people and the

events that shaped so much of the American psyche for

the succeeding century. Many of us may be able to

relate to a pioneer family traveling by wagon train

along the Oregon Trail and appreciate learning about

their everyday lives. Museum objects, journal accounts,

and artists’ depictions are enhanced by seeing the ruts

that their wagon left in the prairie, and the rock where

they stopped to scrawl a record of their passing. 

Whether or not our family ancestors had similar 

experiences, we may come to a better appreciation of

our common past and its power. Much of this 

1

Partners in Tourism and Travel Industry Association of America, 1998, 1999.
A D V I S O R Y C O U N C I L O N H I S T O R I C P R E S E R V A T I O N

A M E R I C A ’ S C H A L L E N G E

4

evidence is contained on Federal lands, lies in public

collections, or is embodied in the public works 

p rojects or military past of former generations.

Increasing Personal Enrichment 

and Knowledge

L e a rning comes from experience, as well as fro m

books and other written sources. Television, film, and

e l e c t ronic media have become increasingly import a n t

over the last 50 years. But we know that the written

or spoken word, and even the visual image, can only

take us so far. If “a picture is worth a thousand

w o rds,” then being able to say, “On this spot...” must

be worth substantially more. In order to truly understand the past we need something more than written

and photographed histories.

For example, many books have been written about the

1876 Battle of the Little Bighorn, popularly known as

“Custer’s Last Stand,” and eyewitness testimony is even

available. From the painted buffalo skin representations and recorded oral histories of the Cheyenne and

Lakota, we may also attempt to view the battle through

Native Americans’ eyes. 

But if we really want to know something about this piece

of history, we need to experience southern Montana on a

hot day in late June, when the slightest movement kicks

up dust and raises a sweat. We need to walk in the valley

of the Little Bighorn River where the Lakota and the

N o rt h e rn Cheyenne families were camped before Custer

o rd e red the attack. We need to climb along the ridges and

gullies over which the 7th Cavalry and Indian warr i o r s

fought. We need to experience the actual place.

We revel in the “genuine article”—the truly memorable

experience that only the actual place can provide.

George Washington commanded the Continental Army

from this tent. Martin Luther King began his public

ministry and civil rights campaign in this neighborhood. Thomas Edison worked on his experiments in

this laboratory. Chief Joseph and the Nez Perce people

established their winter camp and pitched their tipis

here. The Hindenburg dirigible was berthed in this

hangar and exploded over this spot. 

Real places, material objects, and the other “connective

tissue” of history—photographs, maps, diaries, and

other artifacts—give pattern, texture, and a richness to

the past that goes beyond the schoolroom. Either by

accident or design, the Federal Government owns or

manages many of these sites, objects, and archives.

In Summary

In 1966, Congress wrote in the National Historic

Preservation Act that “the spirit and direction of the

Nation are founded upon and reflected in its historic

heritage,” and that “the historical and cultural foundations of the Nation should be preserved as a living part

of our community life and development in order to give

a sense of orientation to the American people.” 

We may not feel that we have an obligation to learn fro m

or appreciate the past. But if we are ignorant of our history and ignore or undervalue our historic re s o u rces, we

miss many important opportunities—to enhance our lives,

to pre s e rve diversity, to establish our identity, and to learn .

In short, we miss opportunities to derive inspiration, spiritual fulfillment, and tangible benefits from our past. We

need to pre s e rve enough of history ’s physical reminders so

that we can appreciate the values they embody. If we fail

to do this, the struggles and achievements that resulted in

the America of the third millennium will remain a closed

book to us—a book that is in danger of being “re m a i nd e red,” sold at far less than its true value, allowed to fall

a p a rt, or even discarded and burned with the trash.

We must also meet our responsibility to protect our public investments. The American people have a vested interest in their publicly owned historic re s o u rces, including

major public buildings, public engineering works, defense

and re s e a rch installations, and other capital impro v ements. The public value of many of these re s o u rces is

enhanced by the broad patterns of our history that they

re p resent as well as particular historic events associated

with them. Many historic re s o u rces in public hands have

value not only to the Nation as a whole, but also to local

communities and gro u p s .

Tre a s u red historic re s o u rces can become focal points to

anchor local economies and engage community spirit
C A R I N G F O R T H E P A S T M A N A G I N G F O R T H E F U T U R E

A M E R I C A ’ S C H A L L E N G E

5

and pride. Such investments in our past must be maintained. Given these many potential benefits, we should

not allow such re s o u rces to deteriorate and be discard e d

if reasonable alternatives to such action exist. 

ABOUT THIS REPORT

This report focuses on the myriad ways in which the

Federal Government influences the preservation of our

heritage through its stewardship of public resources.

Federal agencies that own or manage historic resources

have these stewardship responsibilities. By law, all

Federal agencies must also consider historic values in

their planning and decision making.

But today, the Federal Government is having a hard

time taking care of many of the Nation’s re s o u rces for

which it is responsible. It is having trouble funding

basic programs and sustaining its stewardship eff o rt s

responsibly and cost-eff e c t i v e l y. It is struggling to

meet the basic operating and maintenance needs of its

facilities and public re c reation areas. And in the face

of other needs, Federal agencies often neglect, overlook, or misunderstand their responsibilities as good

public stewards. 

Too often pre s e rvation of historic re s o u rces is not aff o rded enough priority by agencies. In some cases such

re s o u rces may be viewed not as assets but as management

liabilities that strain agency budgets and personnel.

Decisions made about the disposition of such re s o u rc e s

may not fully take into account their potential use or their

overall historic value to local communities or the Nation.

The reasons for these situations are varied and complex,

and solutions are not straightforw a rd. 

For the past two years, the Advisory Council on

Historic Pre s e rvation, the independent Federal agency

c h a rged with advising the President and Congress on

historic pre s e rvation matters, has been studying how

the Federal Government could do a better job of caring for the historic re s o u rces it administers. The

C o u n c i l ’s contribution to the Millennium observ a n c e

is to offer its advice on historic pre s e rvation policies

and implementation strategies that may better serv e

f u t u re stewardship needs of the Federal Government. 

The Council devoted a series of regular meetings to

first-hand examination of historic resources and issues

of concern to Federal managers. The meetings were

held in Miami, Florida; Alexandria, Virginia; Santa Fe,

New Mexico; Honolulu, Hawaii; Washington, DC;

Knoxville, Tennessee; Phoenix, Arizona; and Portland,

Maine. Information collected during these meetings

was augmented by agency presentations and written

comments, public testimony, discussions with agency

preservation personnel, and research. 

The Council also solicited grassroots input from a

broad range of government officials, interested organizations, and individuals via a discussion forum on our

Web site. Federal employees, State and local officials,

Native Americans, citizen activists, historic preservation professionals, business owners, and members of

the interested public shared ideas and opinions through

this medium. Council staff experience also added

important insights.

The re p o rt that follows reviews the richness and diversity

of Federal heritage holdings around the country, and off e r s

examples of the challenges faced by many Federal agencies

in managing these re s o u rces. It looks in detail at four are a s

that are essential to better Federal steward s h i p — l e a d e rship, commitment, accountability, and collaboration—and

suggests how Federal responses to these challenges might

be improved. The re p o rt concludes with a series of general

findings and recommendations for future action.

Our study does not purport to examine all aspects of

Federal policy and experience as they relate to preservation of our past, nor have we been able to examine

all Federal land and property holding agencies in depth

with our own limited resources. However, we have

endeavored to provide a useful overview as well as a

series of focused examples of Federal agency program

activity as a starting point for future discussion and

debate. The Council hopes this report can help chart a

new direction for Federal stewardship of historic and

cultural resources in the 21st century.
C H A P T E R 2

F E D E R A L S T E W A R D S H I P O F A M E R I C A ’ S H E R I T A G E —

A C O N T E X T

HOW DID THE FEDERAL 

GOVERNMENT GET INTO THE 

PRESERVATION BUSINESS?

The important role that the Federal Govern m e n t

could play in the pre s e rvation of historic re s o u rc e s

was first acknowledged in the late-19th and early

20th centuries. The first national parks and monuments, for example, were designated in the 1870s and

1880s to set aside and protect special places and keep

them in the public domain. Civil War battlefields and

Native American antiquities also benefitted fro m

early protection. 

An early and forceful advocate of conservation of 

public lands and re s o u rces was President Theodore

Roosevelt, who recognized the value of stewardship as

a Government re s p o n s i b i l i t y. Early in the 20th century, Roosevelt called for responsible asset management

and long-term enhancement of the value of those

assets. It was due to his encouragement that the

Antiquities Act was passed in 1906. In 1916, the

National Park Service (NPS) was created to administer

many of the early park and battlefield areas and take

c a re of protected western antiquities. 

During the 1930s and 1940s, the Federal Govern m e n t

became more involved in pre s e rvation, conserv a t i o n ,

and public history through such New Deal pro g r a m s

as the Civilian Conservation Corps, the Wo r k s

P ro g ress Administration, and the Federal Wr i t e r s

P roject. Many of the Federal Govern m e n t ’s park holdings, public works, and military installations were also

developed or improved during this period. In the wake

of World War II and the population and development

boom that followed, the effects of growth and new

c o n s t ruction on America’s cities, towns, and countryside energized concerned citizens, who began to seek a

new and more comprehensive approach to pre s e rv i n g

A m e r i c a ’s heritage. 

T h i rty-five years ago, a special committee of the U.S.

C o n f e rence of Mayors, in concert with the congre ssionally chart e red, nonprofit National Trust for

Historic Pre s e rvation, the White House, and several

p rominent members of Congress, produced a re p o rt

and plan of action entitled With Heritage So Rich.

This publication led to the drafting and passage 

of the National Historic Pre s e rvation Act (NHPA) 

in 1966.

NHPA is a comprehensive piece of legislation that

establishes a Federal historic preservation policy, sets

forth broad Federal responsibilities to identify, evaluate, and protect historic resources, identifies key programs that will be followed by the Federal

Government, and defines the role of Federal, tribal,

State, and local government in advancing these policies.

In addition to mandating direct Federal responsibility

for what it owns or manages, a large percentage of historic preservation activity is supported through a public-private partnership established by NHPA. The partnership involves State Historic Preservation Officers

(SHPOs) in each State and territory, Tribal Historic

Preservation Officers (THPOs), and certified local governments (CLGs). At the Federal level, NPS administers

some Federal funding on a matching basis, maintains

the National Register of Historic Places, and runs a

variety of programs that offer technical assistance and

set standards in the identification, evaluation, and

treatment of historic resources. 

An independent Federal agency, the Advisory Council

on Historic Pre s e rvation, reviews Federal actions and

administers a process to ensure consultation between

Federal agencies, tribes, States, localities, and the private sector in Federal planning and decisions that may

a ffect historic re s o u rces. The SHPOs, THPOs, and the

m o re than 1,100 CLGs operate State, tribal, and local

p rograms and oversee subgrants of Historic

P re s e rvation Fund monies under NPS administration.

NPS and the States jointly oversee Federal tax incentives for rehabilitation of historic commercial pro p e rt y. The National Trust for Historic Pre s e rvation, chart e red by Congress in 1949 (but no longer re c e i v i n g

regular Federal appropriations) leads a coalition of

statewide and other pre s e rvation organizations, supp o rts grassroots pre s e rvation eff o rts, and pro m o t e s

historic pre s e rvation through a broad array of fund

raising and outreach eff o rts. 

A D V I S O R Y C O U N C I L O N H I S T O R I C P R E S E R V A 6 T I O N
C A R I N G F O R T H E P A S T M A N A G I N G F O R T H E F U T U R E

F E D E R A L S T E W A R D S H I P O F A M E R I C A ’ S H E R I T A G E

7

FEDERALLY OWNED OR MANAGED 

HISTORIC RESOURCES

The activities of Federal land- and property-managing

agencies have a combined impact on hundreds of millions of acres of public lands, hundreds of thousands of

buildings and other holdings, and their adjacent communities. As a baseline for comparison purposes, it is

estimated that the Federal Government owns, manages,

or administers more than 665 million acres of land, and

430,000 buildings with a floor area of nearly 2.9 billion square feet. It rents an additional 2,030 square

miles, and 77,000 buildings with 300 million square

feet of space. A great many of these public assets have

historic or cultural value of major significance.

It is true that the United States sets aside some special

places, many of them historic, as National Park Units,

public museums, or conservation lands to help pre s e rv e

our heritage. But the re s o u rces for which the Federal

G o v e rnment has stewardship responsibilities are far

m o re extensive than that. National Park Units comprise

only slightly more than 11 percent of Federal lands, a

small fraction of the total Federal holdings thro u g h o u t

the country. The remaining publicly owned and administ e red land and re s o u rces under the trusteeship of various

d e p a rtments and agencies account for nearly a third of

the land area of the U.S. They comprise numerous building complexes, stru c t u res, facilities, and other re s o u rc e s ,

including a wide range of historic artifacts and public

a rt; historic ships, aircraft, and historical collections; and

historic document archives. 

These Federal lands and other pro p e rty include units of

the National Park System, National Forests, National

Wildlife Refuges, and National Marine Sanctuaries. But

they also include the vast public lands throughout the

West and Alaska under the administration of the Bure a u

of Land Management, and the military installations of

the Defense Department. The launch, training, testing,

and tracking facilities of the National Aeronautics and

Space Administration (NASA) are Federal holdings.

Federally owned or controlled Coast Guard stations and

maritime navigation lights and other aids, air traff i c

c o n t rol facilities, re s e a rch laboratories and experimental

facilities, flood control dams and navigation locks,

h y d roelectric facilities, and nuclear power plants are

also included. Veterans Medical Centers and national

cemeteries are a large part of the inventory too. All told,

the Federal Government controls nearly three billion

s q u a re feet of building space, including post offices and

c o u rthouses, prisons, office buildings, U.S. mints, and

Federal re s e rve banks. 

As designated by the National Register of Historic

Places, the Nation’s official list of historic properties

w o rthy of pre s e rvation, Federal historic re s o u rc e s

include a broad range of buildings, structures, sites,

landscapes, and areas significant in American history,

a rc h i t e c t u re, arc h e o l o g y, engineering, and culture .

Historic or archeological districts may comprise hund reds of individual pro p e rties. Collectively, these

resources embody, celebrate, and represent important

historic events; capture and symbolize the lives of persons significant in our past; include examples of period

architecture, industrial design, and historic construction techniques; reflect the work of master craftsmen,

designers, and engineers; and can tell us about the past

and make an important contribution to knowledge of

our own history, prehistory, and culture.

As of March 21, 2000, there were 71,636 pro p e rties 

listed in the National Register of Historic Places, including

both privately and publicly owned re s o u rces. Of these,

10,783 were historic districts, and the number of contributing re s o u rces within these and other listed pro p e rt i e s

was 1,127,364. (Archeological re s o u rces and pro p e rties of

traditional cultural or religious importance were substantially under- re p resented in these known re s o u rces.) Some

properties designated or worthy of designation as

National Historic Landmarks have outstanding national

significance and possess “exceptional value or quality in

illustrating or interpreting the heritage of the United

S t a t e s . ”2 A p p roximately 2,300 pro p e rties had been designated by the Secre t a ry of the Interior as National Historic

Landmarks. Less than 10 percent of these formally re c o gnized and documented re s o u rces are in Federal ownership,

in spite of the vast holdings of the Federal Govern m e n t .

2

36 CFR Part 65, “National Historic Landmarks Program.”
A D V I S O R Y C O U N C I L O N H I S T O R I C P R E S E R V A T I O N

F E D E R A L S T E W A R D S H I P O F A M E R I C A ’ S H E R I T A G E

8

It is difficult to determine exactly how many of these

resources are Federally owned and managed, and even

more difficult to know how many historic resources

exist in Federal ownership that have never been fully

identified, evaluated, documented, and registered. We

know that there are many properties in Federal ownership or control that have not been listed that contain

important archeological resources or antiquities, and

there are also many significant but unregistered Native

American sites containing human remains, associated

or unassociated funerary objects, sacred objects, or

objects of Native American cultural patrimony. Similar

caveats would apply to sites, places, and other properties of traditional religious and cultural importance to

Indian tribes or Native Hawaiian organizations. 

The Council recently requested information fro m

Federal agencies on their historic pre s e rvation holdings

or pro g r a m s .3 Responses and their completeness have

been spotty, and partial results of Council inquiries and

re s e a rch are shown in Figures 4, 5, and 7 (pages 12, 14,

and 60). With some exceptions, we must conclude that

Federal agencies do not have a good understanding or

re c o rd of the myriad historic re s o u rces that they must

manage, and thousands—some estimate the number in

the millions—of historic re s o u rces may exist on Federal

lands but have not yet been identified and documented. 

FEDERAL STEWARDSHIP MANDATES

Both Federal legislation and several Executive orders supp o rt historic pre s e rvation as a national policy, and define

a Federal role for carrying out this policy. The National

Historic Pre s e rvation Act declares that “the spirit and

d i rection of the Nation are founded upon and reflected in

its historic heritage,” and that “the pre s e rvation of this

i rreplaceable heritage is in the public interest so that its

vital legacy of cultural, educational, esthetic, inspirational, economic, and energy benefits will be maintained

and enriched for future generations of Americans.”4

Title I of NHPA lays a policy foundation for Federal

agencies (see Figure 2, page 9). NHPA goes on in Section

110 to lay out a comprehensive framework for pro g r a m s

to carry out national pre s e rvation policy in support of

Federal stewardship. Section 110 directs Federal agencies

to “assume responsibility for the pre s e rvation of historic

p ro p e rties which are owned or controlled by such

a g e n c y, ”5 and to establish and carry out pre s e rvation programs to meet these and the other purposes of the law

(see Figure 3, p. 10). Executive Order 11593 (“Pro t e c t i o n

and Enhancement of the Cultural Environment”) dire c ted the Federal Government to provide leadership in this

e ff o rt, and specifically to “administer the cultural pro p e rties under their control in a spirit of stewardship and

t rusteeship for future generations.”6In later amendments

to NHPA, much of Executive Order 11593 was codified

and incorporated into the law. 

In addition, by law Federal agencies are required to

consider the effects of their actions, including financial

assistance, licensing, and approvals, on historic

resources and engage in public consultation with a variety of concerned parties as part of their decisions on

those actions. Under Section 106 of NHPA, 

the head of any Federal agency having direct or 

i n d i rect jurisdiction over a proposed Federal or federally assisted undertaking in any State and the head

of any Federal department or independent agency

having authority to license any undertaking shall,

prior to the approval of the expenditure of any

Federal funds on the undertaking or prior to the

issuance of any license, as the case may be, take into

account the effect of the undertaking on any district,

site, building, stru c t u re, or object that is included in

or eligible for inclusion in the National Register. The

head of any such Federal agency shall aff o rd the

A d v i s o ry Council on Historic Pre s e rvation established under Title II of this Act a reasonable opportunity to comment with re g a rd to such undert a k i n g.

7

3 Advisory Council on Historic Preservation Memorandum to Federal Preservation Officers, May 9, 2000. 

4 NHPA Sections 1(b)(1) and 1(b)(4) (16 U.S.C. 470).

5 NHPA, Section 110 (a) (1) (16 U.S.C. 470 h-2).

6 E.O. 11593, Section 1.

7 NHPA, Section 106 (16 U.S.C. 470f).
F E D E R A L S T E W A R D S H I P O F A M E R I C A ’ S H E R I T A G E

F I G U R E 2

C A R I N G F O R T H E P A S T 9 M A N A G I N G F O R T H E F U T U R E

The Advisory Council on Historic Preservation, an

independent Federal agency that advises the President

and Congress on historic preservation matters, oversees

and administers Section 106 of NHPA, and issues government-wide regulations that govern its implementation. State Historic Preservation Officers and Indian

tribes play key roles in consulting with and advising

Federal agencies as they meet these responsibilities. 

Agencies are also responsible for considering the

impact of their actions more broadly on the enviro nment in accordance with the National Enviro n m e n t a l

Policy Act (NEPA). Major Federal actions “significantly affecting the quality of the human enviro nment” must be examined to determine whether less

damaging alternatives exist, and detailed analyses prep a red to assist in decisions about those actions.

Impacts on historic re s o u rces are included along with

other environmental factors.

Agencies are re q u i red to protect and control the re m o v a l ,

d e s t ruction, or defacement of significant re s o u rces on their

lands under the Antiquities Act, the Arc h e o l o g i c a l

R e s o u rces Protection Act, and the Native American

Graves Protection and Repatriation Act. (These laws

apply not only to Federal pro p e rt y, but also to those lands

held in trust for Indian tribes.) Agencies that manage land

or operate Federal facilities have a variety of other re s p o nsibilities as well, including both general enviro n m e n t a l

p rotection statutes and more specific land-use planning

and facilities management re q u i rements. The Bureau of

Land Management, for example, is governed by the provisions of the Federal Land Policy Management Act; the

U.S. Forest Service, by the National Forest Management

Act. Building and facility managers have re s p o n s i b i l i t i e s

related to planning, construction, operations, and maintenance of the stru c t u res and installations under their

c h a rge, such as those contained in the Federal Pro p e rt y

and Administrative Services Act and related authorities. 

NATIONAL HISTORIC PRESERVATION POLICY 

Under the National Historic Preservation Act of 1966 (Section 2), Federal agencies are directed to:

■ use measures, including financial and technical assistance, to foster conditions under which our 

modern society and our prehistoric and historic resources can exist in productive harmony and fulfill

the social, economic, and other requirements of present and future generations;

■ p rovide leadership in the pre s e rvation of the prehistoric and historic re s o u rces of the United States and

of the international community of nations and in the administration of the national pre s e rvation pro g r a m

in partnership with State, Indian tribes, Native Hawaiians, and local govern m e n t s ;

■ administer federally owned, administered, or controlled prehistoric and historic resources in a spirit of 

stewardship for the inspiration and benefit of present and future generations;

■ contribute to the preservation of nonfederally owned prehistoric and historic resources and give maximum encouragement to organizations and individuals undertaking preservation by private means;

■ encourage the public and private preservation and utilization of all usable elements of the Nation’s

historic built environment; and

■ assist State and local governments, Indian tribes and Native Hawaiian organizations, and the National Tru s t

for Historic Pre s e rvation to expand and accelerate their historic pre s e rvation programs and activities.
F E D E R A L S T E W A R D S H I P O F A M E R I C A ’ S H E R I T A G E

FEDERAL AGENCY HISTORIC PRESERVATION PROGRAMS UNDER SECTION 1108

Section 110 of the National Historic Preservation Act sets out the broad historic preservation responsibilities of Federal agencies and is intended to ensure that historic preservation is fully integrated into the ongoing programs of all Federal agencies. This intent was first put forth in the preamble to the National Historic

Preservation Act upon its adoption in 1966.

When the Act was amended in 1980, Section 110 was added to expand and make more explicit the statute’s statement of Federal agency responsibility for identifying and protecting historic pro p e rties and avoiding unnecessary

damage to them. Section 110 also charges each Federal agency with the aff i rmative responsibility for considering

p rojects and programs that further the purposes of NHPA, and it declares that the costs of pre s e rvation activities

a re eligible project costs in all undertakings conducted or assisted by a Federal agency.

The 1992 amendments to NHPA further strengthened the provisions of Section 110. Under the law, the head

of each Federal agency must do several things. First, he or she must assume responsibility for the preservation of historic properties owned or controlled by the agency. Each Federal agency must establish a preservation program for historic properties’ identification, evaluation, nomination to the National Register, and

protection. Each Federal agency must consult with the Secretary of the Interior (acting through the director

of the National Park Service) in establishing its preservation programs. Each Federal agency must, to the

maximum extent feasible, use historic properties available to it in carrying out its responsibilities. 

The 1992 additions to Section 110 also set out some specific benchmarks for Federal agency preservation 

programs, including:

■ historic properties under the jurisdiction or control of the agency are to be managed and maintained

in a way that considers the preservation of their historic, archeological, and architectural values;

■ historic properties not under agency jurisdiction or control but potentially affected by agency actions

are to be fully considered in agency planning;

■ agency preservation-related activities are to be carried out in consultation with other Federal, State,

and local agencies, Indian tribes, Native Hawaiian organizations, and the private sector;

■ agency procedures for compliance with Section 106 of NHPA are to be consistent with regulations

issued by the Advisory Council on Historic Preservation; and

■ an agency may not grant assistance or a license or permit to an applicant who damages or destroys

historic property with the intent of avoiding the requirements of Section 106, unless specific 

circumstances warrant such assistance.

F I G U R E 3

A D V I S O R Y C O U N C I L O N H I S T O R I C P R E S E R V A 1 0 T I O N

8 National Park Service, Federal Register, April 24, 1998.
C A R I N G F O R T H E P A S T M A N A G I N G F O R T H E F U T U R E

F E D E R A L S T E W A R D S H I P O F A M E R I C A ’ S H E R I T A G E

1 1

T h e re are special provisions for dealing with pro p e rt y

acquisition and leasing, as well as for surplus pro p e rt y

and transfers of pro p e rty out of Federal ownership.

Statutes like the Public Buildings Cooperative Use Act

made it possible for the General Serv i c e s

Administration and other agencies to enter into cooperative arrangements with non-Federal parties for the

management and use of public buildings. More re c e n tl y, Executive Order 13006 (“Locating Federal

Facilities on Historic Pro p e rties in Our Nation’s

Central Cities”) re a ff i rmed a Federal commitment to

leadership in the pre s e rvation of historic re s o u rces and

p re f e rence for using historic pro p e rties in central cities

for Federal facilities.9

Finally, all agencies have some basic public responsibilities for preservation and maintenance of archival

records that reflect the history and operation of each

agency, and special rules and procedures may apply to

stewardship of Federal artwork, historic furnishings,

museum collections, and other historic holdings.

HISTORIC PRESERVATION 

POLICIES AND PROGRAMS

Federal agencies have adopted a variety of policies and

o rganizational schemes for meeting their historic

p re s e rvation responsibilities. To d a y, a number of

Federal agencies and programs are focused on various

aspects of cultural heritage preservation and enhancement, and attempt to comply with the Federal mandates governing them. Most active among Federal

departments and agencies that own, control, or manage

land and property are the Department of Interior, the

Department of Agriculture, the Department of Defense,

and the General Services Administration.

The Department of Energ y, the Department of

Commerce, and the U.S. Postal Service, which is not

c o n s i d e red a Federal agency but an “independent

establishment of the Executive Branch” under the

Postal Reorganization Act, also have large property

holdings. Key constituent bureaus of these departments

and other responsible agencies are listed in Figures 4

and 5 (pages 12 and 14). Each of these agencies has

stewardship responsibilities for the land and public

property it owns or manages.

As re q u i red to implement Section 110, the National Park

S e rvice has issued standards and guidelines for Federal

agency historic pre s e rvation pro g r a m s .1 0 The standard s

summarize the statutory re q u i rements, and spell out the

principal perf o rmance measures on which to judge

Federal agency programs (see Figure 3, page 10). 

The standards are :

1 . Each Federal agency establishes and maintains a

historic pre s e rvation program that is coord i n a ted by a qualified Pre s e rvation Officer; and that

is consistent with and seeks to advance the purposes of the National Historic Pre s e rvation Act.

The head of each Federal agency is re s p o n s i b l e

for the pre s e rvation of historic pro p e rt i e s

owned or controlled by the agency.

2 . An agency provides for the timely identification

and evaluation of historic pro p e rties under

agency jurisdiction or control and/or subject to

effect by agency actions.

3 . An agency nominates historic properties under

the agencies’ jurisdiction or control to the

National Register of Historic Places.

4 . An agency gives historic properties full consideration when planning or considering approval of

any action that might affect such properties.

5 . An agency consults with knowledgeable and 

concerned parties outside the agency about its 

historic preservation-related activities.

9 Executive Order 13006 was codified in the most recent amendments to the National Historic Preservation Act in May 2000 

(NHPA Amendments of 2000, P.L. 106-208, Section 110 (a) (1) (16 U.S.C. 470h-2(a)(1))).

10 National Park Service, The Secretary of the Interior’s Standards and Guidelines for Federal Agency Historic Preservation Programs

Pursuant to the NHPA, 63 FR 79, 20495-20508, April 24, 1998.
F E D E R A L S T E W A R D S H I P O F A M E R I C A ’ S H E R I T A G E

F I G U R E 4

A D V I S O R Y C O U N C I L O N H I S T O R I C P R E S E R V A 1 2 T I O N
F E D E R A L S T E W A R D S H I P O F A M E R I C A ’ S H E R I T A G E

C A R I N G F O R T H E P A S T 1 3 M A N A G I N G F O R T H E F U T U R E

F I G U R E 4 ( C O N T I N U E D )
F E D E R A L S T E W A R D S H I P O F A M E R I C A ’ S H E R I T A G E

C O M PARISON OF FEDERAL PROPERTY MANAGING 

AGENCY HISTORIC PRESERVATION PROGRAMS*

F I G U R E 5

A D V I S O R Y C O U N C I L O N H I S T O R I C P R E S E R V A 1 4 T I O N

D e p a r t m e n t / Program P r e s e r v a t i o n Separate Full-Ti m e

A g e n c y U m b r e l l a O f f i c e r Employees/Budget 

A l l o c a t i o n * *

A G R I C U LT U R E

F o rest Serv i c e R e c re a t i o n Senior Pro f e s s i o n a l 300/$13.9 million

D E F E N S E

Air Forc e E n v i ro n m e n t† Deputy Assistant Secre t a ry 30/$6.3 million

A rm y E n v i ro n m e n t† Deputy Assistant Secre t a ry 40/$10.2 million

A rmy Corps of Engineers E n v i ro n m e n t Senior Pro f e s s i o n a l 120/$15 million

Marine Corps F a c i l i t i e s Deputy Assistant Secre t a ry

N a v y F a c i l i t i e s† [ s a m e ] 22/$4.3 million

E N E R G Y F a c i l i t i e s† Senior Manager 7 / $ 8 3 0 , 0 0 0

GENERAL SERVICES R e s o u rc e s†† Senior Pro f e s s i o n a l 6/$1.8 million

A D M I N I S T R AT I O N

I N T E R I O R

B u reau of Land Management R e s o u rc e s Senior Pro f e s s i o n a l 160/$13.4 million

B u reau of Reclamation F a c i l i t i e s† Senior Pro f e s s i o n a l 32/$7 million

Fish and Wildlife Serv i c e R e s o u rc e s Senior Pro f e s s i o n a l 20/$2 million

National Park Serv i c e R e s o u rc e s† Senior Manager/Pro f e s s i o n a l 721/$64 million

N A S A F a c i l i t i e s† Senior Pro f e s s i o n a l n o n e

TENNESSEE VA L L E Y R e s o u rc e s Senior Manager 6 / $ 6 0 0 , 0 0 0

A U T H O R I T Y

T R A N S P O RTAT I O N

Coast Guard E n v i ro n m e n t Senior Manager n o n e

U.S. POSTAL SERV I C E F a c i l i t i e s Senior Pro f e s s i o n a l n o n e

VETERANS AFFA I R S F a c i l i t i e s Senior Pro f e s s i o n a l n o n e

Explanatory notes for Figure 5:

* Federal agency historic re s o u rce holdings and programs not depicted in Figures 4 and 5 include: Department of Health

and Human Services (Indian Health Service, National Institutes of Health, Public Health Service); Department of 

Justice (Bureau of Prisons); Department of State; Department of Tr a n s p o rtation (Federal Aviation Administration); 

D e p a rtment of the Tre a s u ry (U.S. Mints, Federal Reserve Bank); Smithsonian Institution.

* * S t a ffing and budget figures (FY 2000) approximate; some agency estimates based on principal known accounts, 

and may not include special short - t e rm projects, fund transfers, or secondary duty assignments.

† Agencies with separate History offices for agency history.

†† Agency with special Arts and Arc h i t e c t u re off i c e .
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6 . An agency manages and maintains historic pro pe rties under its jurisdiction or control in a manner

that considers the pre s e rvation of their historic,

a rchitectural, archeological, and cultural values.

7 . An agency gives priority to the use of historic

properties to carry out agency missions.

Each Federal agency is required to designate a Federal

Preservation Officer to coordinate matters of historic

p re s e rvation and statutory compliance within the

agency. These individuals and other staff who have

responsibilities for historic resources and related programs are located in many places within Federal agency

structures, and have varying degrees of agency-wide

authority and responsibility. Some are in environmental

management or policy offices; others are part of facilities or real estate management divisions. 

A few are at the Assistant Secretary or Deputy Assistant

Secretary level, and others are senior professionals in 

history, architecture, archeology, or a similar field. 

For some agencies separate offices are devoted to 

historic preservation and historic resource stewardship,

and field staff are located in regional, State, district, or

unit offices with advisory, rather than line, responsibility to and through senior managers such as Park

Superintendents, Forest Supervisors, or Installation

Commanders. Some agencies have organized preservation expertise to have maximum effect in policy making, budget formulation, and crisis management.

Preservation boards or internal advisory groups have

proven helpful in some instances. Other agencies have

e n t e red into cooperative relationships with State

Historic Preservation Officers, Indian tribes, academic

institutions, or pre s e rvation organizations at the

regional, State, or local level to enhance their ability to

meet resource management and other needs.

Many, if not most, preservation services are obtained

through contracts and consultant services, but most

land or property managing agencies have some form of

internal operating manual, procedures, and other policy and technical guidance intended to establish the

framework for resource management, planning, and

decision making about historic resources for which the

agency is responsible. In some cases, national or regional Programmatic Agreements or Memoranda of

Understanding help to meet this need while also serving

to document an agency’s statutory compliance under

NHPA, NEPA, or other laws. 

Budget allocations and funding for historic re s o u rc e

s t e w a rdship vary considerably, both as a percentage of

total agency budgets as well as how distinct or separate

it is as a budget line item. In many cases agencies have

little or no funds earmarked for these activities, and must

rely entirely on real estate, facilities management, operations, planning, or environmental compliance accounts.

In other cases some funding is set aside, or “fenced,” but

is largely inadequate to meet the myriad needs. 

HOW WELL HAS THE FEDERAL 

GOVERNMENT BEEN DOING?

Since NHPA was amended in 1992, and then during

and following publication of the standards and guidelines, a number of agencies have worked to impro v e

their policies and programs as well as their compliance with historic pre s e rvation mandates. In spite of

substantial pro g ress by some agencies, no Federal

agency has yet developed an internal historic pre s e rvation program that meets all of the various re q u i rements of Section 110, and no agency has form a l l y

taken steps to consult with the Secre t a ry of the

Interior comprehensively about its program as

re q u i red by Section 110. 

The agency that most closely meets the program standard envisioned by Section 110 is the National Park

Service itself, for its operation and management of the

individual units of the National Park System, although

continuing downsizing, reorganization, and decentralization of some NPS program activities, coupled with a

growing list of maintenance, visitor services, natural

resource protection, and similar program priorities,

have affected NPS’s ability to meet its historic preservation responsibilities. To a greater or lesser degree, the

Bureau of Land Management and the Forest Service
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have relatively strong programs in place, although both

agencies have been under program and funding stress

and are more effective and active in some parts of the

country than in others.

A number of other Federal agencies have been making

significant pro g ress in establishing effective Section

110 programs in recent years. The Council has been

actively working with several of these agencies to

i m p rove deficiencies the agencies themselves have re cognized. These agencies include the Department of the

A rm y, the Department of Energ y, and the General

S e rvices Administration. 

Some agencies, most notably those responsible for larg e

tracts of public land, quite naturally place a high priority

on archeological inventory and archeological re s o u rc e

p rotection on lands under their jurisdiction or contro l .

They also correctly emphasize the concerns of Native

Americans for identifying and protecting pro p e rties of traditional cultural and religious importance. BLM, the

F o rest Service, the Tennessee Valley Authority, and the

Fish and Wildlife Service have historically fallen into this

c a t e g o ry. On the other hand, agencies whose missions

entail greater responsibility for facilities or complexes that

contain important historic buildings and stru c t u re s

include the Air Force, the Arm y, the Navy, the Depart m e n t

of Veterans Affairs, the General Services Administration,

the National Aeronautics and Space Administration, and

the Postal Service. These agencies typically focus on developing operations and maintenance pro c e d u res for planning and carrying out repairs and rehabilitation work on

the buildings and stru c t u res they manage. 

Program organization and staff expertise may therefore

focus on archeological resources at the expense of the

built environment, or vice versa. This relative focus,

while completely logical and appropriate, may lead to

problems when a facility manager has to deal with

a rcheology or places of significance to Native

Americans. Conversely, a public land manager may be

faced with a large and deteriorating historic structural

complex to manage, and not have the experience or

agency resources to address the issue. 

Recent Policy Reviews and Investigations 

Several studies have examined agency progress in meeting historic preservation program responsibilities. A

1988 examination by the General Accounting Office

(GAO) reviewed the status of historic preservation programs at six Federal agencies: the Forest Service, the

B u reau of Land Management, the National Park

Service, the General Services Administration, the Postal

S e rvice, and the Veterans Administration (later

renamed Department of Veterans Affairs). The report

found that because of their different sizes and missions

as well as other agency priorities, the agencies had

mixed results in locating, inventorying, and nominating

historic properties, and were having difficulties in using

their historic buildings for program purposes. All of the

agencies were also having problems in adequately protecting, preserving, and maintaining some of their 

historic properties. 

As GAO noted: “This has resulted in deterioration or

damage of historic pro p e rties, including those of

national and international significance.... Agency officials generally agreed that their agencies’ compliance

with the historic preservation requirements of the

amended act could be improved. However, they also

believe they need better guidance and support from

Interior and specific program funding.” 11

As previously mentioned, amendments were made to

N H PA in 1992 to strengthen its program pro v i s i o n s ,

and two sets of Section 110 guidelines and other

technical guidance have been issued by the National

Park Service to assist agencies in meeting their

responsibilities. In 1996, both the Council and the

National Park Service were asked about Federal

agency pro g ress in developing historic pre s e rv a t i o n

p rograms by Congressman James Hansen, Chairm a n

of the Subcommittee on National Parks and Public

Lands, Committee on Resources, U.S. House of

R e p resentatives. Both agencies gave mixed reviews to

agency program activities and pro g ress in compliance

with the law, although the National Park Service was

m o re positive and hopeful about recent pro g ress than

the Council. 

11 General Accounting Office, Implementation of Federal Historic Preservation Programs Can Be Improved (GAO/RCED-88-81), 1988.
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While there have been many improvements in some agencies, such as the Department of Defense, over the last thre e

years other internal agency audits and external, independent examinations of some agency re s o u rce management

p rograms have pointed out serious problems. These have

included two Departmental Inspector General re p o rts, one

f rom the Department of the Interior and one from the

D e p a rtment of Agriculture, pointing out serious deficiencies. The Bureau of Land Management cultural re s o u rc e

i n v e n t o ry program and its management of cultural collections were singled out,1 2 as was the Forest Serv i c e ’s data

collection and environmental analysis for timber sales.1 3

Independent critiques have also included several General

Accounting Office re p o rts on problems with Federal

p ro p e rty management, including needed repairs and

alterations of Federal buildings,1 4 and deficiencies and

p roblems in military housing and attempts to privatize

that infrastru c t u re need.1 5 Outside re p o rts have focused

on deterioration of the National Park System,1 6 o ff e red a

detailed and case-specific indictment of the operations

and activities of the U.S. Army Corps of Engineers,1 7 a n d

p roduced an expert examination of broad deficiencies in

the management of Federal facilities.1 8

Previous Council Studies 

In the last decade, the Council prepared two specialized

studies focusing on particular issues and agencies. 

The first study, responding to a request from the House

Committees on Science, Space, and Technology and

Interior and Insular Affairs, Subcommittee on National

Parks and Public Lands, analyzed issues related to the

a p p ropriate role of historic pre s e rvation in decision making about the operation and management of highly 

scientific and technical facilities.1 9

The re p o rt focused on NASA and grants made by the

National Science Foundation, although it also examined

c e rtain related facilities and agency policies in other

d e p a rtments (e.g., the Air Force, the Department of

E n e rgy). Findings and recommendations in the re p o rt

emphasized the need for a reasonable balance to be

s t ruck between the operational and re s e a rch needs of

active scientific and technological facilities, and the

l o n g - t e rm pre s e rvation, management, and public interp retation of the physical reminders of America’s historic

heritage in science and technology. 

The Council’s second study, submitted to the Secre t a ry of

Defense, examined the Defense Depart m e n t ’s adherence to

the National Historic Pre s e rvation Act.2 0 The re p o rt was

conducted in cooperation with, and with financial assistance from the Department of Defense in conjunction with

the Legacy Resource Management Program. At that time,

the Council found a re c o rd of inconsistent legal compliance and program administration; poor understanding,

12 DOI OIG, Audit Report, Cultural Resource Management, BLM, Report #99-I-808, September 1999.

13 USDOA OIG, Evaluation Report, Forest Service Timber Sale Environmental Analysis Requirements, Washington, DC, 

Report #08801-10-AT, January 1999.

14 GAO, Report to Subcommittee on Economic Development, Public Buildings, Hazardous Materials, and Pipeline Transportation,

Committee on Transportation and Infrastructure, U.S. House of Representatives, Federal Buildings: Billions Are Needed for Repairs 

and Alterations, GAO/GGD-00-98, March 2000.

15 GAO, Report to Congressional Committees, Military Housing: Continued Concerns in Implementing the Privatization Initiative,

GAO/NSIAD-00-71, March 2000.

16 Sharon Buccino, Charles Clusen, Ed Norton, and Johanna Wald, Reclaiming Our Heritage: What We Need to Do to Preserve America’s

National Parks, Natural Resources Defense Council and National Trust for Historic Preservation, July 1997. 

17 Jeff Stein, Peter Moreno, David Conrad, and Steve Ellis, Troubled Waters: Congress, the Corps of Engineers, and Wasteful Water Projects,

Taxpayers for Common Sense and National Wildlife Federation, March 2000.

18 Committee to Assess Techniques for Developing Maintenance and Repair Budgets for Federal Facilities, Board on Infrastructure and the

Constructed Environment, and Commission on Engineering and Technical Systems, National Research Council, Stewardship of Federal

Facilities: A Proactive Strategy for Managing the Nation’s Public Assets, National Academy Press, Washington, DC, 1998.

19 Advisory Council on Historic Preservation, Balancing Historic Preservation Needs with the Operation of 

Highly Technical or Scientific Facilities, Report to Congress, February 1991.

20 Advisory Council on Historic Preservation, Defense Department Compliance with the National Historic Preservation Act: 

Section 202(a)(6) Evaluation Report, March 1994.
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s u p p o rt, and appreciation for historic re s o u rce stewardship; and low priority devoted to funding, staffing, and

planning related to historic resource management.

The Defense Department has been working since then to

c o rrect many of these deficiencies.

Common Concerns

General problems in how agencies discharge their 

s t e w a rdship responsibilities to historic re s o u rces can be

attributed in part to reduced budgets, downsizing,

reduced availability of experienced staff (some of whom

have been reassigned elsewhere), and agency or pro g r a m

re o rganization. In addition to absolute numbers of staff

and size of budgets for historic re s o u rce stewardship, the

placement, authority, re s p o n s i b i l i t y, and expertise of

p re s e rvation staff, as well as opportunities of these 

personnel to influence budgets and other decisions, are

critical factors in how well or how poorly Federal 

s t e w a rdship of historic re s o u rces is carried out. 

As financial and personnel re s o u rces have gro w n

scarcer, increased conflicts between primary mission

activities and historic preservation mandates have been

a factor in the ability of some agencies to address overall historic resource stewardship needs and Section 110

program goals. Many agencies have had to focus their

remaining limited staff and funding on other legislative

mandates, which unlike Section 110, have statutory

time frames and a potential threat of legal action. 

For example, agency compliance with the re q u i rements of the Native American Graves Protection and

Repatriation Act (NAGPRA) has had a substantial

impact on Federal land managing agencies since it was

passed in 1990. Agencies have had to develop inventories of human remains, cultural items, and objects of

cultural patrimony held in Federal collections, and

consult with Indian tribes, Native Hawaiian org a n i z ations, and others about repatriation and related issues.

Agencies in some parts of the country, including some

B u reau of Land Management offices, have also stated

that they may spend up to 90 percent of their staff time

and re s o u rces reacting to survey and impact analysis

re q u i rements and consultation needs to meet their

Section 106 compliance responsibilities. This, in their

opinion, severely limits their ability to develop 

p roactive stewardship programs, including onsite

i n t e r p retation and public education.21 

Unlike the detailed reporting requirements associated

with NAGPRA, there is currently no requirement,

either in NHPA or elsewhere, for agencies to report on

their holdings or the progress they are making with

identification and evaluation of historic resources in

general. Such a requirement does exist for archeological resources;22 however, archeology provides only a

part of the picture. The Secretary of the Interior does

p re p a re a re p o rt on threatened and endangere d

National Historic Landmarks, but a similar reporting

requirement on significant threats to properties included in or eligible for the National Register of Historic

Places23 has never been implemented by Interior due to

lack of funding and personnel. 

Heritage asset reporting, now required of agencies with

their other stewardship reports of assets and liabilities

under the Chief Financial Officers Act, has begun but is

in its infancy, and agencies are having a hard time collecting information and providing meaningful and useful assessments of this data. Agencies need to have systems in place to quantify and describe the broad and

full range of resources for which they have stewardship

or planning responsibilities under Section 110.

For those Federal agencies that have jurisdiction or cont rol over re s o u rces, knowledge of and appreciation for

the vast extent and diversity of their holdings varies cons i d e r a b l y. Some have responsibilities for particular types

21 State protocols under a nationwide agreement with the Council and the National Conference of SHPOs may eventually help to streamline

protection work and permit more attention to proactive management activities. Similar cooperative results are anticipated from agreements

with Indian tribes.

22 Under Section 5(c) of the Archeological and Historic Preservation Act of 1974, P.L. 93-291, the Secretary of the Interior is charged with

preparing an annual report to Congress on archeology.

23 NHPA, Section 101 (a)(8).
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of historic re s o u rces more than others (e.g., lighthouses,

dams, post offices, or scientific re s e a rch facilities), 

while most either manage, plan for, or consider the

full range of historic re s o u rces that either meet the criteria for listing in the National Register of Historic

Places, or are cultural artifacts, historic objects, and

a rchival materials. 

As previously mentioned, when asked many agencies

are hard-pressed to provide specific information on the

number, type, and level of significance of all of their

historic resource holdings, let alone an assessment of

their condition or potential mission use. Properties that

are already listed in the National Register of Historic

Places are known and documented by agency preservation specialists, including Federal properties contributing to larger historic districts in local communities.

However, sites and structures that have had some evaluation but have not been studied in detail are more difficult to characterize, and resources that have not been

thoroughly evaluated or otherwise described but are

known to exist on lands under agency jurisdiction or

control are far more problematic. The extent to which

this information is adequately maintained in management databases, disseminated to other agency technical

specialists, or made known to decision makers varies

substantially.

Recent studies also suggest that the vast majority of

both federally and non-federally managed or owned

lands remain unsurveyed (between 90 and 95 percent). For those Federal agencies that account for

m o re than 85 percent of the Federal land base—

B u reau of Land Management, Forest Service, Fish and

Wildlife Service, and NPS—the majority of their 

historic re s o u rce holdings are archeological sites, but

all of these agencies are responsible for a wide range

of districts, sites, buildings, stru c t u res, and objects as

well. Some agencies have provided somewhat more

detailed (but still problematic) estimates, and such

i n f o rmation is reflected in Figure 4 (page 12). 

On the agency program side, as partially depicted 

in Figure 5 (page 14), less than one percent of 

c o n g ressionally appropriated dollars, and less than onetenth of one percent of Federal employees, are devoted

to full-time historic and cultural site pre s e rvation work.

Many employees have related environmental management, planning, or review responsibilities as an “extra”

d u t y, often only vaguely related to their other duties,

training, and expertise. Archival and museum pre s e rv ation occupies perhaps another one-tenth of one perc e n t

of employees. 

CONCLUSION

In spite of the important stewardship responsibility

entrusted to Federal agencies for much of our Nation’s

heritage, other agency mission priorities often force historic preservation activities, programs, funding, and

staffing to take a back seat. Some agencies see historic

resources as integral to their public programs and legislative mandate, while others do not. Protection, use,

and related activities often remain underfunded and

understaffed. The reasons for this situation are varied;

the solutions are not readily apparent. A more detailed

examination of issues and problems that are being

faced by many of the agencies may help to indicate

areas for improvement and change.
C H A P T E R 3

C H A L L E N G E S O F F E D E R A L S T E W A R D S H I P —

T H E M E S A N D V A R I AT I O N S

In order to gain a better sense of some of the challenges facing Federal agencies in their management of historic re s o u rc e s

and how that management relates to agency missions, the

A d v i s o ry Council on Historic Pre s e rvation met with agency

re p resentatives and other interested parties and toured local

Federal facilities or lands. The meetings included the following locations (principal agency focus is shown in bold):

■ November 5-6, 1998, Santa Fe and Los Alamos,

New Mexico (D e p a rtment of Energ y; Civilian

C o n s e rvation Corps/National Park Service; Indian

tribes)—Los Alamos National Laboratory, Pueblo

of Jemez, and National Park Serv i c e

I n t e rmountain Support Office 

■ F e b ru a ry 10-12, 1999, Honolulu, Hawaii

(D e p a rtment of Defense, including Departments of

the Army and Navy; Native Hawaiians; statewide

p re s e rvation org a n i z a t i o n s ) — F o rt Shafter,

Schofield Barracks, Makua Maneuver Range, and

Naval Base Pearl Harbor

■ June 24-25, 1999, Washington, DC (G e n e r a l

S e rvices Administration; White House

Millennium Council)—General Post Off i c e / Ta r i ff

Building, the Ariel Rios Federal Building, the John

Wilson Building (DC Mayor and City Council

o ffices), and the Ronald Reagan Intern a t i o n a l

Trade Center and Federal Building 

■ November 15-17, 1999, Knoxville, Oak Ridge, and

G reat Smoky Mountains National Park, Te n n e s s e e

(D e p a rtment of Energ y; National Park Serv i c e;

Tennessee Valley Authority)—Oak Ridge National

L a b o r a t o ry, Great Smoky Mountains National Park,

and Tennessee Valley Authority Headquarters, Norr i s

■ M a rch 9-10, 2000, Phoenix, Arizona (B u reau of

Land Management; U.S. Forest Serv i c e) — B u re a u

of Land Management Arizona State Office, To n t o

National Forest, Agua Fria National Monument

■ June 22-23, 2000, Portland and Augusta, Maine

(U.S. Coast Guard)—Casco Bay lighthouses and

the Maine State Capitol

Information gathered in conjunction with these meetings, as well as other data and observations about

Federal stewardship, was used to inform the following

discussion. Examples of some of the challenges faced

by Federal agencies are arranged around six themes

that focus attention on related resource types and issues

facing their managers:

■ Public buildings;

■ Scientific and technological facilities;

■ Military and related installations;

■ Multiple-use public lands;

■ National parks and other preserves; and

■ Public works and infrastructure.

Additional attention in this chapter is focused on two

special topical areas: special landmarks, and issues of

particular concern to Native Americans.

THE GOVERNMENT’S LANDLORD 

AND PUBLIC BUILDINGS

General Services Administration

The General Services Administration, an independent

agency, is responsible for 455 historic public buildings,

with more than 55 million square feet of building

space. This amounts to nearly one-fourth of all of the

space in the inventory of GSA’s Public Buildings

Service, and does not include a number of other historic

resources under GSA management (such as portions of

the African Burial Ground under and around the Foley

Square Federal Annex in downtown Manhattan, New

York City). In the Washington, DC, area, for example,

GSA’s National Capital Region has more than 70 historic buildings, many of them constructed over a relatively short period of time as the central core of Federal

Government headquarters offices. 

Many of GSA’s historic re s o u rce stewardship re s p o n s i b i lities are carried out by its regional offices, with advice and

guidance from headquarters offices that bring a national

policy perspective and centralized support. Recent re n ovation work on the Ariel Rios Federal Building in

Washington offers an interesting case example: upholding

historic integrity while improving energy eff i c i e n c y, and

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upgrading and modernizing mechanical and electrical

systems, proved challenging. Conservation of building

materials, incorporation of fire and life safety impro v ements without damage to the building’s historic character,

and sensitive design based on a carefully developed

Historic Stru c t u res Report all proved critical in the success of the approach. The Public Building Serv i c e ’s new

a p p roach to this and other historic pre s e rvation pro j e c t s

relies on upgrading existing building elements where 

possible rather than expensive total makeovers. 

GSA sets out its comprehensive historic pre s e rv a t i o n

p rogram in Held in Public Tru s t ,2 4 a study that was

a l ready in preparation on how GSA could improve its

own program and more effectively meet its steward s h i p

responsibilities for the historic re s o u rces in its inventory.

Copies of the study were distributed to Council members

to inform their subsequent discussion. Held in Public

Tru s t recommends GSA’s adoption of more eff e c t i v e

ways to integrate historic re s o u rce stewardship into the

a g e n c y ’s business approach to providing and maintaining Federal work space. Key issues examined and highlighted include a reinvestment philosophy for historic

buildings, flexible application of codes and design stand a rds, quality assurance for design and constru c t i o n ,

enhancing employee education and tenant aware n e s s ,

early consultation on projects with communities and

review groups, and using building pre s e rvation plans for

planning and decision making. 

The study includes a variety of recommendations—

policy, business processes, technical research priorities,

p a rtnership approaches, and training and re c o g n ition—for better managing GSA’s historic assets. The

intent is to ensure the viability of these historic

resources and their attractiveness within the agency’s

funding limitations, and emphasize the value of careful

and appropriate daily maintenance and repair of historic properties through the development and use of

Building Preservation Plans and other basic tools.

Such authorities as Section 111 of NHPA and the

Public Buildings Cooperative Use Act of 1976 establish

mechanisms for making Federal Government properties available through leases, exchanges, and cooperative ventures for both commercial and not-for-profit

purposes, while protecting and enhancing their historic

values. P ro p e rties transferred out of Federal ownership,

with appropriate conditions for long-term pre s e rv a t i o n ,

maintenance, and use, must also be considered. For the

renovation and adaptive reuse of the General Post

O ff i c e / Ta r i ff Building in Washington, DC, which had

long been unoccupied and unused, GSA held a ro u n dtable and public forum on viable reuse options for the

National Historic Landmark with assistance from the

National Building Museum and others. Historic pre s e rvation and ensured public access were two primary

goals of the initiative. The roundtable re i n f o rced the

i m p o rtance of the building both architecturally and in

its urban context. 

As a result, the building will be leased to a private 

commercial developer, renovated, and reconfigured to

meet the needs of a first-class hotel, given its historical

prominence, architectural features, and close proximity

to the Washington, DC, Convention Center and other

sites. GSA hopes to use this sort of process for other

buildings in its inventory where appropriate, and when

possible supplement Federal tax dollars with private

funds and management to help meet stewardship and

other public needs. 

One area that has presented challenges to GSA over the

years is the courthouse modernization and design program. GSA tries to work closely with the Federal judicia ry to ensure appropriate and sensitive design that meets

not only security, privacy, and needs of Federal judges

and the U.S. Marshals Services but also historic pre s e rvation needs. Unfort u n a t e l y, the extent of public involvement and consultation, the amount of consideration

GSA has been able to aff o rd adaptive use of existing historic buildings, and the degree of flexibility incorporated

in the planning and design process have been inconsistent from a pre s e rvation point of view. Prominent re c e n t

cases include, on the one hand, San Diego, Californ i a ,

which may result in demolition of the historic Hotel San

24 Held in Public Trust, General Services Administration, Public Buildings Service, 1999.
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Diego on a prominent downtown site, and an arg u a b l y

m o re successful result in Gulfport, Mississippi, which

will gut and reuse the former Gulfport High School for

U.S. Attorney and Probation Services offices adjacent to

the new courthouse stru c t u re. 

Because of its Federal leadership role in real pro p e rt y

management, GSA has also developed real pro p e rt y

asset management principles that it has made available to other Federal agencies. Issued in 1996, these

principles are summarized as:

Use what you have first. Real property assets under the

custody and control of the Federal Government should

be considered first when accommodating Federal

agency mission requirements.

Buy only what you need. The amount of interest in

Federal real pro p e rty assets should be the minimum nece s s a ry to effectively support a Federal agency’s mission.

Use industry-like instruments of agreement. Real property assets of the Federal Government should be utilized among agencies with the use of instruments of

agreement that follow the best practices of the industry.

Reinvest. Reinvestment in a real property asset is essential to maintain its fair market value and its ability to

benefit from advancements in business practices and

technologies, and to support the Federal mission and

enhance employee productivity.

Strive for income/expenses comparable to the market.

Any income realized by a real pro p e rty asset during its

useful life should approximate that generated by a comparable commercial pro p e rty; while any expense by such

an asset during its life cycle should approximate that

i n c u rred by a comparable commercial pro p e rt y.

Maximize use among agencies. The maximum utility of

a real property asset can be realized if it is continuously transferred among agencies having mission needs

while it is under the control of the Federal Government.

Ensure timely disposal. A Federal property asset that

has no further mission support use by the Federal

Government should be disposed of in a timely manner

that best serves the public interest.

Retain proceeds from disposal and outleasing. The proceeds gained from the disposal of a Federal real pro p e rt y

asset, or from outleasing, should be available for use by

the agency having custody, control, and use of the asset.

P rovide professional training. Federal employees should

be given the training needed to perf o rm their jobs at the

highest level of professionalism, and in order to utilize

models and other analytical tools for optimizing their

real pro p e rty asset management decisions.2 5

GSA has continued to examine these principles since

they were issued, to ensure that they are interpreted

and implemented in ways that are sympathetic to and

consistent with stewardship of historic resources. At

the same time, GSA has also developed a new approach

for many of its landmark Federal office buildings and

courthouses. Called “First Impressions,” these projects

have incorporated landscaping, signage, lighting, and

other design elements to make them attractive and welcoming to the public, an active contributor to the local

street scene, and a desirable environment for tenants.

Historic and artistic displays have been placed in lobbies and other public areas, and associated brochures

about the buildings and their history are being made

available to tenants and the public. 

Under the Federal Pro p e rty and Administrative Serv i c e s

Act, as amended, and pro p e rty regulations, GSA has continued to administer much of the surplus pro p e rty pro c e s s

for the Federal Government. This has often resulted in

historic re s o u rces being re p o rted to GSA as “excess to

agency needs” by other Federal agencies, and then left to

GSA to be disposed of by being sold or transferred fro m

Federal ownership. Special provisions make it possible

for some historic re s o u rces to be off e red at no cost to

State and local governments for “historic monument”

and re c reational purposes, with National Park Serv i c e

25 “Federal Real Property Asset Management Principles,” GSA Bulletin D-240, Office of Governmentwide Real Property Policy,

General Services Administration, 61 FR 201, 53925-53929, October 16, 1996. 
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review and involvement. Requirements for such 

consideration include submission of a use plan, financial

plan, and architectural plan, and any pro p e rty changes

must be consistent with the Secre t a ry of the Interior’s

S t a n d a rds for Rehabilitation. Many former military facilities, such as coastal gun emplacements and bunkers, were

t r a n s f o rmed into State and local parks by this means.2 6

As military base closure and realignment developed into

an important Federal Government priority in the late

1980s, Congress gave the authority and re s p o n s i b i l i t y

for this activity directly to the Department of Defense.

H o w e v e r, GSA remains the sole Federal agency with

explicit authority to place protective covenants on pro pe rty involved in such transfers. As a consequence, GSA

has played a continuing yet significantly reduced role in

such transfers, while the Department of Defense has

taken on major responsibilities for closing installations,

finding potential new users, disposing of their holdings,

and assisting local communities with “economic adjustments” to the accompanying loss of Federal employment

f rom these installations. 

U.S. Postal Service

A number of the buildings that fall under GSA’s

responsibility were originally built as combined spaces

for U.S. post offices and courthouses. The Post Office

Department was one of the original branches of the

Federal Government, under Benjamin Franklin. Today,

the U.S. Postal Service is “an independent establishment of the executive branch” under the terms of the

Postal Reorganization Act of 1970 (39 U.S.C. 101 et

seq.). The Council did not pursue discussions with the

Postal Service about its program or the many historic

resources actively used or affected by Postal Service

actions every day, due to Council funding and staffing

limitations as well as the ambiguous legal status of the

Postal Service in the executive branch. However, any

future discussions of Federal stewardship of historic

resources need to include serious consultation with the

Postal Service about its holdings, as well as its policies,

programs, and changing priorities and needs. 

These local landmarks have fallen under increasing pre ss u re because of Postal Service changes in its operations.

The Postal Service maintains some 38,000 postal facilities of various kinds throughout the country. Although it

is not considered a Federal executive branch agency, the

United States Post Office is still viewed by most

Americans as the local embodiment of the Federal

G o v e rnment in their communities, and stewardship of

historic post offices is extremely important. 

By the Postal Serv i c e ’s own estimates, perhaps 1,200 of

its postal facilities—approximately 3 perc e n t — a re individually significant or contribute to a listed historic dist r i c t .2 7 State Historic Pre s e rvation Officers, with the

cooperation of the Postal Service and others, have prep a red thematic historic studies and listed significant post

o ffices in the National Register of Historic Places in

Arizona, Arkansas, California, Colorado, Idaho,

Mississippi, Montana, Nebraska, Nevada, New Mexico,

New York, North Dakota, Oregon, Utah, and Wyoming. 

At the same time, the Postal Service in recent years has

been pursuing an aggressive consolidation and relocation strategy to make its operations more cost-effective.

This has resulted in the closing of many rural post

offices, but has also caused prime downtown post

offices, many of them historic, to be vacated or reduced

to minor substations, while new facilities with better

transportation, carrier route access, and mail handling

facilities are being built in suburban or exurban areas.

Recent legislative proposals have sought to address

some of these concerns, including consideration for

reuse of historic resources in post office relocation projects, but have yet to become law. In addition, the Postal

Service has limited personnel with expertise in the care

of its remaining historic facilities, many of which have

architecturally important lobbies and other interior

spaces, historic murals, ornamental metal work, and

other historic characteristics worth preserving. These

issues could benefit from some focused policy attention

and discussion with Postal Service officials and other

concerned parties. 

26 Since the program’s inception in 1949, more than 100 historic properties, including lighthouses, post offices, customs houses, and 

military holdings, have been transferred for new uses.

27 U.S. Postal Service Preservation Officer, personal communication, September 6, 2000.
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Common Concerns

T h e re are a number of major issues that challenge the

continuing use, reuse, and proper care of Federal historic

buildings for agencies like GSA, the Postal Service, and

others with such holdings.2 8 Maintaining the viability of

the Federal inventory of historic re s o u rces is difficult in

the face of fiscal constraints, a shrinking Federal workf o rce, client or tenant concerns about re t rofitting “old”

buildings in a way that can meet their needs, and

C o n g ressional commitment in light of new constru c t i o n

p re s s u res. Investments already made in the Federal

G o v e rn m e n t ’s historic assets need to be care f u l l y

weighed against demands for new space and “name”

facilities. Balancing security, user safety, and open public

access is and will continue to be challenging, part i c u l a rly for GSA as it works with the Federal judiciary. The

d e s i re for Federal policies that limit or reduce suburban

sprawl and its associated transportation and other costs,

while supporting reuse of historic re s o u rces in urban

downtowns, often seem to be at odds with operational

needs or short - t e rm financing strategies. Finally, all such

agencies must work hard to develop and implement

design standards for new construction that complement

historic buildings and neighborhoods, and work closely

to integrate such plans into the revitalization and “smart

g rowth” eff o rts of local communities. 

SCIENCE, TECHNOLOGY,

AND RESEARCH LABORATORIES

Department of Energy

The Department of Energy (DoE) operates pro g r a m s

related to nuclear weapons re s e a rch and development,

e n e rgy technology, and related technical capabilities for

the science, technology, and national defense. It oversees

or administers nine major laboratory complexes and

other ancillary re s e a rch and development facilities with

a p p roximately 2.4 million acres of land. A number of

these facilities are historically significant for the role they

played in the development of the atomic bomb during

World War II, or their part in post-war weapons 

development and other re s e a rch, and are a unique part of

our Nation’s heritage. Several of the facilities have important archeological areas of traditional importance to

Indian tribes and other Native Americans, or other 

historic re s o u rces that predate Federal ownership. 

Los Alamos, New Mexico, Oak Ridge, Tennessee, and

H a n f o rd, Washington, contain important re s o u rces connected with the Manhattan Project, the World War II

e ff o rt to construct an atomic bomb. A number of these

Manhattan-era facilities and the Government housing

that was built to support them are no longer in Federal

ownership. However, a number of significant facilities

a re, including the V-Site, a simple frame building complex where the A-bomb components were assembled at

Los Alamos.2 9 At Oak Ridge, two enormous complexes, the K-25 and Y-12 sites, each comprised of many

individual buildings and other features, were both

involved in development work on the atomic bomb. The

K-25 complex is no longer active, but is scheduled for

redevelopment; Y-12 is active, and both remain high

security areas. The challenges of pre s e rvation under the

c i rcumstances are substantial.

P a rticularly at DoE’s national laboratories such as these,

continuous additions and modifications to accommodate changing re s e a rch needs have significantly altere d

many original stru c t u res and removed or modified original equipment. Given these changes, it can be challenging to judge the historic value of today’s facility and

what remains worthy of pre s e rvation. Many of these

complexes are also contaminated with radioactive and

other hazardous materials. When a building is placed in

the “surveillance and maintenance” mode for facilities

management purposes, it is generally cleaned of any

contents that could present a hazard over the long-term .

After a building is decontaminated in this way, it is generally secured and left to decay (i.e., “abandoned in

place”) for 25 years. Historic value has not typically

been considered in such decisions.

28 Letter, GSA Administrator to Advisory Council on Historic Preservation Chairman, August 12, 1999.

29 A devastating wildfire begun in nearby Bandelier National Monument in spring 2000 destroyed portions of the V-Site, but the building

where the bomb components were assembled survived. DoE successfully applied for and received a Save America’s Treasures grant to 

preserve the site before the fire, but was having difficulty coming up with the required match. 
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An additional problem relating to DoE’s re s o u rce 

s t e w a rdship is that many of the agency’s facilities are

“ G O C O s ” — G o v e rnment-owned, contractor- o p e r a t e d .

In some cases the contractors are academic institutions,

as at Los Alamos; elsewhere, such as Oak Ridge, private

c o m m e rcial engineering and facilities management companies are involved. Both academic and commerc i a l

facilities managers may not perceive the same management priorities, including historic re s o u rce steward s h i p

responsibilities, that Federal personnel might. 

As DoE closes down the former nuclear weapons 

complex sites, the future of these areas has been publicly debated. For many sites, complete environmental

cleanup, reclamation, and land restoration seems to

have had widespread public support. At Rocky Flats,

Colorado, and Fernald, Ohio, for example, the current

plan is to leave nothing standing, while at Hanford the

plan is to demolish most of the Manhattan Project and

Cold War period facilities except for the B Reactor. In

most of these public discussions, the focus tended to be

on the extent of natural resource protection and public

health, and the potential for industrial, recreational, or

agricultural use, while the historic value of the

resources was rarely discussed. 

One consequence of this is that managers believe the

public does not want DoE to leave much, if anything,

behind when it closes and abandons facilities.

H o w e v e r, as clean up proceeds, some citizens are

beginning to voice concern about the identity of their

community and its history as embodied in the facility

itself. At many sites, including Fernald, Rocky Flats,

and Hanford, there is now growing public interest in

c reating a new museum or partnering with existing

museums, pre s e rving some of the original equipment

and artifacts, and re c o rding interviews with re t i re d

employees for use in documentary films chro n i c l i n g

the history of the facilities.

At Hanford, the strategy has been to group buildings

by category, such as all small buildings or the entire

Plutonium Finishing Plant complex. At the Savannah

River plant in South Carolina, the strategy is to demolish collections of buildings. There is no incentive or

reward for discriminating among these properties to

identify properties or artifacts that are historically

important and might be preserved. 

Field staff and contractors need to be guided and

trained in what properties are appropriate to preserve

because of their historic value, and issues of safety and

security must be dealt with in that context. Where public health is a factor, DoE in particular needs to be able

to allow access to some of the historic resources (such

as the B Reactor at Hanford) without having to spend

millions in restoration if the contamination is contained. This would assume, of course, that the contamination does not present an unreasonable risk to the

public and there are no other security issues. 

In addition, local governments around the complex are

a w a re of the value of historic tourism and are concern e d

about building an alternative revenue base for the

f u t u re. Interest in science, technology, and history

should make the sites involved in the Manhattan Pro j e c t

and Cold War serious destinations for domestic and

i n t e rnational tourists. Alre a d y, more than one quarter of

visitors to the Bradbury Science Museum in Los Alamos

a re from Japan, Germ a n y, Great Britain, and other

countries. Curre n t l y, DoE contractors receive award

fees for each building they take down. A bonus should

be considered for leaving buildings with historic value

standing and finding alternative uses for them, including

possible public visitation or other interpre t a t i o n .

Helping the former Manhattan Project and Cold Wa r

communities establish their heritage could lead to their

fair share of the multi-billion dollar tourist industry predicted for the new millennium. DoE must, however, protect certain classified information and restrict public

access to parts of the sites because of security and operational concerns. In some cases security concerns have

limited historians’ and historic pre s e rvation expert s ’

access to historic documents, artifacts, equipment, and

buildings, and these issues will have to be considered in

such decisions.

D o E ’s management of its lands, often including 

substantial restricted buffer areas to maintain security
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or safety, also needs to be examined care f u l l y. The

agency has an active re s e a rch and management part n e rship with the University of South Carolina, Institute of

A rchaeology and Anthro p o l o g y, for a long-term arc h eological re s e a rch program at the Savannah River site.

The program has identified and conducted re s e a rch on

h u n d reds of archeological sites, and also has an active

public outreach and education component. However, at

other DoE facilities historic re s o u rce management conc e rns have been raised. For example, in critical comments following the Council’s meeting with DoE managers at Los Alamos, re p resentatives of the

Confederated Tribes of the Umatilla Indian Reserv a t i o n ,

speaking pointedly about DoE stewardship at its

H a n f o rd facility near Richland, Washington, noted,

Since the passage of the National Historic

P re s e rvation Act (NHPA), Federal agencies have diligently identified historic pro p e rties; however, longt e rm management of many of these historic pro p e rties has not occurred. This is not unique to DoE,

although the situation in some cases may be worse

because historically DoE is not a land management

a g e n c y. The cultural re s o u rces management deficit is

a glaring reality of cultural re s o u rces management in

the western United States where there are larg e

blocks of federal re s p o n s i b i l i t y, unprotected and subject to constant loss. Cultural re s o u rces managers

have essentially built an industry of NHPA Section

106 clearance priorities and have neglected other

management and stewardship responsibilities. 

The contrast between Hanford and Savannah River is

stark, and management issues like these need to be considered in continuing discussions between the Council

and DoE, as well as in relation to the broader view of

stewardship needs contained in this report. 

During the course of this study, DoE began to take

action to improve its historic resource stewardship. On

October 23, 1998, Secretary of Energy Bill Richardson

established an agency-wide “corporate board” on historic preservation to help meet NHPA requirements

more effectively. The board was also charged with

making recommendations as to how best preserve

DoE’s history, both in writing and through the stewardship of buildings and other historic properties and

equipment, and with reviewing related re s o u rc e

requirements and potential new funding needs. 

At the suggestion of the Council, and with the cooperation and assistance of DoE, a panel of experts was

convened by the Council to offer re c o m m e n d a t i o n s

on the significance of and pre s e rvation options for

the “signature facilities” of the Manhattan project at

Oak Ridge, Tennessee, and Hanford Reserv a t i o n ,

Washington. The Council panel held two additional

site visits, with opportunities for local public input,

at each of the locations. Detailed findings and re commendations were transmitted to DoE Corporate

B o a rd in October 2000, and were under study by

DoE as this re p o rt went to press. The Council panel

o ff e red site-specific, short - t e rm, and long-term program and policy findings and recommendations 

to improve DoE’s stewardship of these important 

historic re s o u rc e s .3 0

National Aeronautics 

and Space Administration 

The National Aeronautics and Space Administration is

responsible for managing research and development in

aeronautics, astronautics, space sciences, and exploration. It is best known for its operation and oversight

of the country’s manned and unmanned space programs. NASA administers nine field centers, including

launch, control, testing, astronaut training, and

research and development facilities. It also has a major

funding and operational role in the Jet Propulsion

Laboratory in Pasadena, California, a federally funded

research and development center. Twenty NASA structures or specialized facilities have been designated as

National Historic Landmarks, and the main Space

Transportation System (space shuttle) launch complex

at the Kennedy Space Center in Florida is listed in the

National Register of Historic Places for its association

with the Apollo manned lunar program.

30 The report was being released to the public as this went to press. For details of the recommendations and DoE’s response to them, 

see Appendix 1 and the electronic version of this report at www.achp.gov.
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NASA takes major steps to document and interpret the

h i s t o ry of the manned and unmanned space pro g r a m s ,

and actively works with nonprofit partnership groups to

facilitate and support publications, video documentaries,

and visitor centers at major NASA centers. Partners or

concessioners operate public walking or bus tours to certain portions of the facilities; many of these facilities are of

historic value and interest. NASA’s History Office used the

celebration of NASA’s 40th birthday in 1998 to inspire a

wide spectrum of commemorative activities, publications,

and special exhibits. Many NASA employees, re t i rees, and

contractors are proud of their history and interested in historic space hard w a re, and video and written accounts of

the manned space program abound. NASA also has in

place a cooperative agreement with the Smithsonian

Institution to allow the National Air and Space Museum

to select hard w a re and artifacts for its collections that

have been determined excess to NASA’s active operational

needs, and portions of these historical collections are on

display at NASA centers and at regional museums. 

For development or test facilities that were used during

previous manned space programs, such as the Apollo

moon program, but that have not been needed since,

NASA’s management approach has tended to be one of

benign neglect unless such extant structures are obstacles to facility improvements or redevelopment for new

technical requirements. Many historic facilities have

been modified and remain in active use; the remainder

are not actively managed, but effectively “abandoned

in place” and occasionally included as part of a special

tour, subject to safety restrictions. In some cases, as

with the beginning of the space shuttle program, more

aggressive plans for demolition, major modification, or

retrofitting have been advanced. Some visitor center

exhibits include historical information on key facilities

or experimental complexes, although they largely concentrate on modern space science applications and

interactive space program demonstrations. 

Launch Complex 39 (containing two launch pads for the

Space Shuttle, 39A and 39B, the massive Ve h i c l e

Assembly Building, and other contributing stru c t u res and

a reas) at Kennedy Space Center, Cape Canaveral, Florida,

is a premier historic re s o u rce as well as an operational

complex. Agreements over the years have made it possible for NASA to upgrade and modify the facilities as

needed. When the Apollo moon program ended and

Space Shuttle operations began, a private fund-raising

e ff o rt to save the Saturn V Launch Umbilical Tower fro m

dismantling and scrapping failed. This tower launched

the lunar missions, but NASA had no further use for it

and did not support its pre s e rvation, citing budget priorities. NASA has generally not viewed protection and

management of “obsolete” facilities as a mission or budge t a ry priority. Continuing use, historic instru m e n t a t i o n ,

equipment, and other unique aspects of these facilities

continues to be threatened by modification or, in the case

of some facilities, abandonment and eventual removal. 

Several of NASA’s National Historic Landmarks 

e l s e w h e re in its system—associated with experimentation, development, and flight control for the manned

space pro g r a m — a re now unused and little or no maintenance is being done on them. One is actively being cons i d e red for demolition, and several have had key pieces

of definitive equipment or instrumentation re m o v e d .

This process is similar to the in-place abandonment, and

eventual dismantling or demolition, that has occurred at

many Energy Department facilities, as well as at Air

F o rce launch and test sites. Managers are not perm i t t e d

to expend maintenance funds on abandoned facilities. 

R e c e n t l y, NASA has become embroiled in a contro v e r s y

involving the telescopes that it supports on the summit of

Mauna Kea in Hawaii. The area is of traditional cultural and religious significance to Native Hawaiians. While

NASA does not own or manage these telescopes, which

a re run by the University of Hawaii, it does provide significant funding for the development, operation, and

re s e a rch use of parts of this complex, and the case is raising the consciousness of the agency with re g a rd to

Native Hawaiian and other potential Native American

i n t e rests and concerns. 

Common Concerns

A number of dilemmas face both DoE and NASA as they

make mission decisions and management choices. For

example, without some source of funding other than

drawing on “overhead” budgets, finding money for 
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historic pre s e rvation activities can be difficult. Over the

past five years, DoE has undergone a strategic alignment

that emphasizes core missions such as defense pro g r a m s

and environmental restoration at the expense of ancillary

activities. NASA has gone through a similar exerc i s e ,

including a re s t ructuring and overall reduction in personnel. In this context, many in DoE have raised the conc e rn that historic re s o u rce stewardship could conflict

with such goals as reducing DoE’s real estate liabilities or

expeditiously remodeling buildings to accommodate the

latest supercomputers or robotic equipment. 

An ancillary problem for both agencies has been safety

a round its facilities, especially those that have been

abandoned for some time. DoE has been struggling with

a series of accidents and injuries in its work force and

has tightened the pro c e d u res entailed in entering and

working on older pro p e rties. These well-intentioned

p ro c e d u res inevitably cause delay and additional costs,

and may result in further impediments to long-term

p re s e rvation as well as public interpretation. 

Both NASA and DoE possess first-of-a-kind or unique

equipment and other artifacts that have great historic

value for education, exhibition, and other purposes.

H o w e v e r, DoE does not have an agreement like NASA has

with the Smithsonian Institution to acquire such equipment for its collections. Much of the historic equipment in

DoE hands is contaminated and/or remains classified, and

will be disposed of as the agency demolishes most of its

Manhattan Project and Cold War era pro p e rties. For art ifacts that could be kept, there is a dearth of appro p r i a t e

storage space throughout the agency despite the availability of some unused buildings. At the Savannah River site,

for example, the historic pre s e rvation office is looking for

a building to store artifacts. Existing buildings curre n t l y

not in use for mission purposes have not been actively

c o n s i d e red because they have been targeted for removal 

as part of a program to reduce building maintenance 

liability and increase operational eff i c i e n c y. 

Overall, a case needs to be made in both agencies 

for the outstanding historic value of many of their

re s o u rces as part of the Nation’s heritage. This 

consciousness-raising needs to be linked to finding creative approaches for funding and other preservation

partnership support.

THE NATION’S DEFENSE AND 

RELATED INSTITUTIONS

The Department of Defense (DoD) has the world’s larg e s t

specialized infrastru c t u re. Roughly the size of the State of

Vi rginia, DoD’s physical plant is worth $500 billion. It

includes not only mission and mission-support facilities,

but also housing for more than 300,000 families and

about 400,000 unmarried service members. DoD is

actively pursuing initiatives for facility strategic planning,

including disposal of obsolete and excess buildings and

s t ru c t u res; base reuse alternatives; the fostering of competition, privatization, and outsourcing, including

i m p rovements to military housing; and integrated 

e n v i ronmental re s o u rce management. 

Federal preservation staff for the military services 

estimate that collectively the services have identified

about 120 historic districts on installations, more than

25,000 pre-1940 buildings, and perhaps as many as

80,000 World War II-era buildings. Innumerable archeological sites, sites of traditional cultural or religious

importance, historic special purpose facilities (such as

space launch complexes), and other historic properties

have been identified or are likely to exist on DoD’s 25

million acres in the United States.

The quantity, quality, and variety of historic resources

under the jurisdiction of DoD is probably rivaled only

by the National Park Service, and most of these remain

in active operational use or on lands used for training

and other purposes. The range of resource types incorporates almost every conceivable class of property,

from historic documents and Native American religious

sites to National Historic Landmark ships, buildings,

and designed landscapes.3 1

All of the services have benefitted considerably over the

last 10 years from the availability of dedicated funds for

31 Defense Department Compliance, pp. 36-37.
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re s o u rce planning and management activities through the

Legacy Resource Management Program. This initiative,

originally created in the Department of Defense

A p p ropriations Act in 1990, has been funded since 1991,

and has permitted DoD to make significant pro g ress in

both natural and cultural re s o u rce conservation eff o rt s .

The program was intended to provide a source of support

for baseline information collection, re s o u rce management

planning, and demonstration projects to improve the

identification, protection, and maintenance of the

D e p a rt m e n t ’s many natural and cultural re s o u rc e s ,

including historic re s o u rces. For example, DoD installations are re q u i red to pre p a re Integrated Plans for natural

as well as cultural re s o u rces. Legacy funding has been

available for such purposes. By the end of FY 1999, DoD

had completed 56 percent of its Integrated National

R e s o u rce Management Plans and 45 percent of its

Integrated Cultural Research Management Plans. 

Installations also conduct cultural re s o u rce inventories

to re c o rd historic and archeological re s o u rces on installation pro p e rt y. The inventories help installations manage such re s o u rces and ensure better protection. They

also help installation commanders and tenant commands

comply with legal re q u i rements. Significant pro g ress has

been made in completing archeological inventories.

A p p roximately 66 percent are now complete, compare d

with 77 percent of historic building inventories.

Overall, DoD and military services’ headquarters have

established good umbrella programs that support a bro a d

p re s e rvation ethic, but major commands, installation

commanders, and tenant commands on those installations must regularly balance re s o u rce pre s e rvation with

their specific mission needs within limited budgets. This is

not a simple or straightforw a rd task, and continues to

p resent significant challenges on both a short - t e rm and

l o n g - t e rm basis. Many of the changes occurring thro u g hout the Defense establishment have presented both

o p p o rtunities and challenges for each of the services, and

they have responded in distinctly diff e rent ways. 

Department of the Army

The Army manages some 12,000 buildings and districts

that are listed in or eligible for the National Register of

Historic Places, including 12 National Historic

Landmarks. In addition, the Army has more than

100,000 known sites of archeological and Native

American cultural importance, all on approximately 12

million acres of land. The vast number and diversity of

historic properties in the Army inventory reflect nearly

all periods in our Nation’s history, from 12,000-yearold archeological resources to buildings and structures

from the Cold War period. An estimated additional

70,000 buildings will require evaluation over the next

30 years. As inventory work continues across Army

installations, the number will undoubtedly increase. 

Through the Army Environmental Center, which serves

as an agency-wide research, development, and advisory

arm on a variety of environmental programs and

responsibilities, the Army has developed a suite of policy, guidance, and Army-wide technical documents.

This has resulted in, potentially at least, one of the most

c o m p rehensive cultural re s o u rce programs among

Federal agencies. A variety of strategies and cooperative approaches are being developed to encourage better military planning and promote more responsive

management of fragile historic and arc h e o l o g i c a l

resources within the military mission context.

Separate from the Army Environmental Center, a new

Office of Army Historic Properties has also been created under the auspices of the Assistant Secretary for

Installations and Environment. The intent is to broaden the Army’s preservation program by increasing the

utilization of historic buildings and improving their

economic viability. As one outgrowth of the base closure and realignment process, and the need to improve

military housing, the Army is working to embrace a

philosophy for its historic built environment that will: 

■ Adapt traditional uses to meet new needs;

■ Pursue innovative funding and operating methods;

■ Integrate historic pro p e rty management and 

planning into daily operations;

■ Engage public, private, and nonprofit partners to

support its goals;

■ Explore and test creative uses—and reuses—for

its historic buildings;
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■ Leverage Army assets with local and State 

g o v e rnment re s o u rces; and

■ Stimulate private investment in pre s e rv a t i o n ,

maintenance, and re u s e .3 2

The range of historic properties the Army manages and

the particular challenges posed by active military installations is illustrated by the U.S. Army Garrison in

Hawaii, which oversees nearly 165,000 acres. Fort

Shafter, located in the greater Honolulu area is, at 94,

the oldest Army post in Hawaii. Schofield Barracks was

constructed in 1909 on what was originally Hawaiian

crown lands to provide a base for the Army’s mobile

defense of Oahu. Makua Military Reservation is a

4,190-acre training area on Oahu used for training

maneuvers and live ammunition fire training. The continued use of these properties has major implications

for Army historic preservation efforts. 

At Fort Shafter, for example, much of the attractive

and desirable housing for General Officers and senior

s t a ff around Palm Circle, near the “Pineapple

Pentagon” (Richardson Hall) that is the historic

H e a d q u a rters of the U.S. Army Pacific, is suff e r i n g

f rom termite infestation. In addition to pest management, re p a i r, upkeep, and ongoing maintenance needs

a re substantial, as are the costs. At Schofield Barr a c k s

in central Oahu, two recent projects have been underway to renovate the Health Clinic (which began life as

a hospital facility in the 1920s), and the Barr a c k s

Quadrangles (“Quads”) that date to World War I. The

latter facilities were featured in the award - w i n n i n g

novel and film, F rom Here to Etern i t y.

At Makua training area in western Oahu, the Army is

faced with managing property containing a number of

threatened and endangered natural species, in addition

to many historic and culturally significant remains of

Native Hawaiian culture (see page 50). One way the

Army has responded is by working with local Native

Hawaiians and other community representatives, and

assembling a community advisory group known as the

Friends of Ukanipo Heiau to help plan and manage its

stewardship of Makua.

Despite the funding that has been available thro u g h

the DoD Legacy Resource Management Program, the

A rmy re p o rts that it is constrained by a lack of funds

designated specifically for cultural re s o u rce management. Defense appropriation bills in each fiscal year

set line-item figures for military personnel, operations

and maintenance, construction, pro c u rement, etc.

Ty p i c a l l y, funding for cultural re s o u rce management

needs is drawn from military construction or operations and maintenance accounts as part of pro j e c t

costs. Pre s e rvation budgets, there f o re, are generally

low and could be diverted to other projects of higher

priority by the commander of a given installation. Low

funding contributes to widespread deferred maintenance of historic buildings and stru c t u res, and neither

Legacy nor other funding has been available to attack

such backlogs. 

The long-term value of historic re s o u rces is still not

widely recognized throughout the Arm y. While policies

re g a rding historic pro p e rties may have evolved, these

changes and new perspectives are not always communicated or embraced across and down the chain of command. In addition, there are special constraints placed

upon certain types of military funding. For example,

t h e re have been legislative limits on the amount of

money that can be spent in a fiscal year on general off icer quarters. This set amount of funding is generally

i n s u fficient to accomplish major rehabilitation or

restoration, actions that are often necessary to re v e r s e

d e f e rred maintenance problems. Proposals to exceed the

funding limit re q u i re congressional appro v a l .

Department of the Navy 

(with U.S. Marine Corps)

The Navy has a significantly smaller land base than

the Arm y, but still maintains a sizeable percentage of

land and shore facilities with more than 3.6 million

owned and leased acres. Most of the responsibility for

historic re s o u rce stewardship rests with the Naval

Facilities Engineering Command, the Navy’s in-house

a rc h i t e c t u re, engineering, and planning arm .

H o w e v e r, the Command can only advise facility, fleet,

and other commanders.

32 “Managing the Army’s Historic Properties: A Blueprint for Preservation and Reuse,” Office of Army Historic Properties, brochure, 1999.
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The Navy and the Marine Corps have an important 

historical legacy in their holdings. These range from 

p rehistoric rock art and archeological sites, to the U.S.

Naval Academy and important naval industrial shipy a rds and support areas of the 19th and 20th centuries.

Bombing and gunnery ranges in Hawaii, Puerto Rico,

and in the Mojave Desert have a history of contro v e r s y,

while being rich in archeological and cultural sites. 

The Navy has been actively engaged in a number of

important activities related to its historic resource stewardship over the last several years. Unlike its sister services, military downsizing and normal obsolescence

requires the Navy to address ship disposal, and some of

these vessels are historic and of interest to nonprofit

organizations and others. The Navy also operates an

underwater resource program that works with the

National Park Service and others on documentation

and other projects. 

One prominent place to examine some of the issues

surrounding Navy stewardship is the U.S. Naval Base

at Pearl Harbor, Hawaii. Designated a National

Historic Landmark in recognition of the December 7,

1941, air attack by Japan as well as the overarching

historical importance of Pearl Harbor in the Pacific

through time, the Pearl Harbor National Historic

Landmark District consists of more than 1,200 buildings and structures constructed during the 100-year

history of the base. The base also contains numerous

Native Hawaiian cultural sites, including remains of

stone-walled fishponds traditionally used for aquaculture. Best known of the Naval Base’s historic resources

are the submerged remains of the USS Arizona and the

USS Utah as well as other reminders from the attack.

Although the USS Arizona memorial is owned by the

Navy and located in the middle of a Navy base, NPS

has the responsibility for managing the memorial and

its visitor’s center and museum. Even more visitors are

now expected with the opening of the USS Missouri

(which hosted the 1945 Japanese surrender), which is

berthed near the Arizona. Following the Missouri’s

final decommissioning in 1992, it remained mothballed

until 1998 when it was moved it to Pearl Harbor to

facilitate creation of the Battleship Missouri Memorial.

Decisions about historic re s o u rces in the context of

naval operations at Pearl Harbor are guided by a 1979

P rogrammatic Agreement among the Navy, the

Hawaiian SHPO, and the Council that has not been

a l t e red or amended since its execution. The Navy is considering major new development at Ford Island, located

in the harbor at the base. Ford Island contains buildings

and stru c t u res associated with its historic use as off i c e r

housing and a naval air station, was the location of

“Battleship Row” during the attack, and has both the

A r i z o n a site and the M i s s o u r i just off s h o re. Runways

and stru c t u res still bear scars from the strafing and

bombing that took place during Japan’s attack.

Traditionally accessible only by ferry, a bridge between

the island and the mainland opened last year that would

facilitate new housing and other development, and consultation on the appropriateness of such re d e v e l o p m e n t

has begun.

In 1997, the Navy completed and adopted revised 

planning guidelines for Historic and Archeological

Resources Protection to ensure that Navy and Marine

Corps installations, bases, and activities plan for and

address integrated resource management needs for historic and other resources. The guidance helps the Navy

and the Marine Corps establish priorities for resources

by categorizing the built environment and assigning

buildings, stru c t u res, and designed landscapes to

appropriate treatment categories. 

The guidance was one fundamental basis for a 1999

P rogrammatic Agreement that deals with undert a kings affecting the built environment at Navy facilities

in the Hampton Roads area of Vi rginia. The agre ement concluded among the Navy, the Vi rginia State

Historic Pre s e rvation Off i c e r, and the Advisory

Council on Historic Pre s e rvation eventually led to a

Nationwide Programmatic Agreement for management of historic family housing units that was signed

in 2000. It establishes basic pro c e d u res and criteria

for identifying, evaluating, and prioritizing pre s e rv ation and ongoing management of historic family

housing units in general, as well as provisions for

dealing with exceptions and special situations on a

case-by-case basis.
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Department of the Air Force

The Air Force, youngest of the services, is also faced

with some significant challenges. The Air Force maintains about nine million acres. Major commands as

well as bases oversee historic resource management,

with technical support from an Air Force Center for

Environmental Excellence located at Brook AFB in San

Antonio, Texas. 

Many Air Force facilities are either former Army or

Army Air Corps facilities. This is the case with the former Wyoming cavalry outpost that is now Francis E.

Warren Air Force Base, as well as the former Army Air

Corps centers at Langley Air Force Base, Virginia, and

Wright-Patterson Air Force Base, Ohio. There are also

some important bases, like Vandenberg and Edwards

Air Force Bases in California, that combine Cold War

period aerospace history and technology with remains

of ancient Native American cultures. 

The Air Force is coping with many of the same issues,

problems, and concerns as the other services. This

includes its changing role in the Nation’s defense posture in the post-Cold War era, with accompanying

changes in strategic nuclear force structure and tactical

air defense. Environmental cleanup and remediation is

a major concern in the Air Force, and potentially could

result in removal or substantial alteration of facilities

dating from the post-World War II period that have not

yet been fully evaluated for their historic value. The Air

Force has been working with the National Park Service

and other partners on a number of specific historic

preservation-related projects at individual installations,

using Legacy Resource Management Program funds.

Examples of two such projects are a historic interpretive trail at Wright-Patterson Air Force Base in Ohio

that was developed in cooperation with a Boy Scout

Eagle Scout candidate, and an onsite interpretive center

with exhibits at a prehistoric Native American site on

F.E. Warren Air Force Base in Wyoming.3 3

Likely to affect all of the military services, but perh a p s

the Air Force in part i c u l a r, are pending decisions on a

National Missile Defense deployment. An enviro n m e n t a l

impact statement was prepared in 2000 that outlines

the possible effects of Ground Based Interceptor placement, new Command and Control facilities, and detection and communication stations. There would be spinoff effects from personnel realignment and construction

of support facilities to augment implementation of this

plan. In addition to archeological resources and traditional properties in some areas, many of the historic

resources that would be affected at installations, particularly those in Alaska, would be of World War II or

Cold War vintage. 

Affiliated Agencies—Veterans Affairs 

and U.S. Coast Guard 

Although the Council did not specifically review the

activities of the Department of Veterans Affairs (VA) or

the Coast Guard (except for lighthouses; see Figure 6

on page 33), each of these entities shares many of the

daily management and operational challenges and concerns regarding stewardship responsibilities with the

Army, Navy, and Air Force. 

The VA’s Veterans Health Administration, through its

Office of Facilities Management, has recently completed (and made available on its Web site) a detailed database and other information on its historic holdings,

which include many important examples of period hospital, group home, and other arc h i t e c t u re at its

Veterans Medical Centers and other facilities. The

availability of this baseline information and technical

guidance may make it less intimidating for property

managers to include historic resource considerations in

their ongoing repair, maintenance, and management

decisions. However, the VA program could benefit significantly from additional support given the wealth of

historic resources in its care and the modern residential

and health care needs of veterans at the facilities. 

The Coast Guard, an agency of the Department of

Tr a n s p o rtation that shares many characteristics and

mission responsibilities with the military services, has

faced similar challenges. Like the Navy, it is primarily

3 2

33 “Conserving Natural and Cultural Resources on Department of Defense Lands: Case Studies from the DoD Conservation Program,”

Technical Notes, Department of Defense, 1999.
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SPECIAL AND DESIRABLE RESOURCES: LIGHTHOUSES AND LODGES

There are certain special resources that are not only highly prized by many Americans, but also capable of

engendering both public and private support for their preservation and care. For a variety of reasons, these

resources are valued, and both public and private entities are often willing to make more extraordinary

efforts to protect, preserve, and promote them and ensure that they remain in public use and accessible. As

such, there may be some lessons to be learned for other Federal stewardship efforts that seek to engage the

public and raise funding, as well as for the setting of Federal funding and management priorities. Fund raising efforts to preserve and rehabilitate major national landmarks such as the Statue of Liberty and Ellis

Island in New York Harbor, the Washington Monument, and similar national icons seemingly stand a 

better chance than garnering broad support and money for lesser known resources.

Lighthouses and their associated outbuildings (collectively known as light stations) are some of America’s

most evocative historic resources, with distinctive designs, colorful histories, and striking maritime settings.

While a number have been transferred out of Federal ownership in recent years, a majority remain under

Federal control, with most administered by the U.S. Coast Guard. 

Over the past three decades, technological advances have permitted the Coast Guard to automate and

“unman” virtually all of its light stations, a change that has saved the Federal Government significant manpower and money. In 1968 the Coast Guard initiated its Lighthouse Automation and Modernization

Program. Over the next 20 years, more than $26 million was spent in automating light stations. The resulting removal of Coast Guard personnel resulted in savings of more than $63 million. Every Coast Guardowned light station is now automated and “unmanned,” except for Boston Harbor Light. (The first light

station in the country, it remains staffed at the specific direction of Congress.) 

At the same time, continuing Coast Guard budget constraints have forced the agency to focus re s o u rces on prim a ry, safety-critical missions such as providing aids to navigation (including thousands of light and sound signals)

and search and rescue. Unfort u n a t e l y, automation and tight budgets have combined to create problems for historic

light stations that are no longer manned or lived in, including deferred maintenance and in some cases vandalism.

Withdrawal of keepers and staff, while fiscally responsible, ended the day-to-day maintenance, repairs, and

oversight that historic light stations had previously enjoyed. By the 1980s, it became apparent that this situation was taking its toll on the protection and maintenance of these properties. To address this, the Coast

Guard expanded its policy of leasing light stations, which had been instituted in the 1960s. Lessees of historic light stations, which are generally nonprofit organizations, assume responsibility for maintenance and

rehabilitation and are able to encourage and manage public visitation.

But leasing has proven not to be the only answer. The Coast Guard has also transferred ownership of light 

stations to other parties while retaining easements to operate the needed navigational aids. A number of

such transfers have been authorized through special legislation, notably for numerous lighthouses in the

State of Maine. Such transfers bring a needed influx of commitment and funds from other parties to the

challenge of light station pre s e rvation. Legal impediments remain, however, to using this approach as a

c o m p rehensive solution. ( c o n t i n u e d )

F I G U R E 6

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In the 105th Congress, legislation was introduced to remove those barriers. Reintroduced in the 106th

Congress, the National Historic Lighthouse Preservation Act (P.L 106-355) amended the National Historic

Preservation Act to establish a national historic light station preservation program.3 4 Central to the law was

establishment of a process that would encourage and facilitate transfer or sale of historic light stations to

non-Federal parties, with appropriate review.

Transfer of light stations out of Federal ownership, while retaining easements for the Coast Guard to 

operate needed aids to navigation, offers several possible benefits from a historic preservation perspective.

Leasing to non-profits has generally not benefitted remote light stations, many of which are offshore and

have limited public accessibility. Transfer or sale of such lights may offer the best opportunity to ensure their

continued preservation. Even light stations that are already leased may benefit from transfer. Ownership of

the property can provide leverage and incentive that may otherwise be lacking for major preservation fund

raising and projects.

National Park lodges a re also among the most visible, and often prized historic stru c t u res in Federal hands.

Available for visitor accommodation, their upkeep and operation are not without controversy because their locations are in highly visible natural environments. A recent “coffee table” book, G reat Lodges of the We s t , h i g hlights 11 of these stru c t u res, 10 in the National Park System and one in a National Forest. Maintenance, re p a i r,

and modernization work has been challenging, and not the least of the problem has had to do with funding the

work. A variety of creative approaches has been taken, usually in cooperation with the non-governmental 

manager or concessioner for the facility, and often with the assistance of “friends” groups. 

But these are the most visible and readily supportable of national park historic structures. As Richard Moe,

President of the National Trust for Historic Preservation, summarized in the foreword to that book:

Glacier National Park, to cite a single example, is home to more than 300 stru c t u res. Many of them are in

serious peril. The Sperry and Granite Park chalets, built early in this century to provide a unique visitor

experience in Glacier’s remote backcountry, have been closed to the public since 1992 out of concern for

e n v i ronmental and visitor safety. The famous Many Glacier Hotel...is still in service at present—but it could

s h a re the same fate in the near future unless extensive structural repairs are made. The cost of re s t o r i n g

these three buildings alone is estimated in the millions of dollars.3 5

In National Forests, there are few grand lodges, but there are many cabins and abandoned fire lookouts that

are no longer essential to Forest Service operational needs, but are extremely popular with the public.

Recreation Cabin Rentals is a popular Forest Service program through which the public can rent cabins and

lookouts for overnight stays. Heritage specialists are actively involved in restoring the historic structures for

use in the program and making sure information is available to the visiting public about the history of the

structure and surrounding area.

F I G U R E 6 ( C O N T I N U E D )

A D V I S O R Y C O U N C I L O N H I S T O R I C P R E S E R V A 3 4 T I O N

34 Passed by Congress and signed into law by the President on October 24, 2000.

35 Great Lodges of the West, Christine Barnes, W.W. West, Bend, Oregon, 1997.
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c o n c e rned with sea and air operations rather than its

s h o re facilities. Large Coast Guard installations like

G o v e rnors Island in New York harbor, which has closed

and is being made available for local re c reation and private development, are being abandoned in favor of

much smaller local facilities and shore support stations. 

Neither the VA nor the Coast Guard have more than a

few professional cultural resource staff specifically

assigned to assist with their activities or to participate

in planning and decisions affecting local facilities. In

addition, the Department of Defense has had a basic

advantage from its special program and funding support over the last decade through the Legacy Resource

Management Program. Specialized training on historic

preservation for Coast Guard and DoD personnel in

1997 and 1998, developed by the Council in partnership with the Navy’s Civil Engineer Corps Officers

School, has at least helped to raise awareness of historic

resource stewardship needs and legal requirements. 

Common Concerns

All of the military services and their related agencies are

working to improve the efficiency and effectiveness of

historic stru c t u re management and protection, in some

cases with urg e n c y. For example, under the Wherry

M i l i t a ry Housing Act of 1949 and the Capehart

Housing Act of 1955, approximately 250,000 housing

units were built over 13 years to fill a critical housing

s h o rtage among the military services. Constructed with

private funds on lands leased from the Federal

G o v e rnment, these family residences were based on

civilian models of the time. The same designs of houses,

a p a rtments, and rowhouses were often built as military

c o n s t ruction pro j e c t s .

DoD is now deciding how to deal with this aging housing stock, much of which considered substandard by

modern standards, and may become (if it has not

a l ready) a factor in military personnel re t e n t i o n

through re-enlistments. DoD is also attempting to

determine whether any of the remaining complexes

(34,000 Army units, 25,300 Navy units, 36,900 Air

Force units, and 11,500 Marine Corps units) may be

considered historic, while it pushes ahead on privatized

housing initiatives that could eventually result in 

substantial new construction and affect other historic

resources. The majority of military family housing

extant today was built before 1969, and nearly 10 percent is 50 years old or older. Housing replacement, construction of new housing, privatization of housing for

military families, and maintenance, repair, rehabilitation, and retention of historic housing will be major

issues in the new millennium. The Navy’s nationwide

agreement has explicit provisions for dealing with

many of these concerns, but no such agreements have

yet been developed for the other services. 

In California, DoD used Legacy Resource Management

P rogram funds to sponsor and review previous historic

building and stru c t u re studies. DoD is using the review as

one basis for planning completion of historic pro p e rt y

inventories, as well as for heightening military personnel

a w a reness. The project, involving 93 installations, 39 of

which have closed or are closing, is a cooperative venture

among DoD, the four services, the California SHPO, 

the Advisory Council on Historic Pre s e rvation, the

National Park Service, and the govern o r’s Office of

Planning and Researc h .

The study found that inventory and evaluation was 

complete at one-third of the installations, partially complete at one-third, and not begun at the re m a i n d e r. To

date, however, more than 3,600 historic re s o u rc e s

appear to meet National Register criteria, and four are

National Historic Landmarks. The services are using the

knowledge to improve management of these import a n t

re s o u rces and ensure their continued pro t e c t i o n .

Beginning in the mid 1980s, a major DoD eff o rt to

remove World War II “temporary” wood frame buildings

originally constructed in the 1940s, combined with a

detailed look at the state of the military ’s housing stock,

led to some major questions about the condition and

a p p ropriate use of DoD’s historic and cultural assets at its

installations throughout the continental United States. 

S h o rtly there a f t e r, the end of the Cold War in 1989 

p recipitated major changes in the military. A large forc e

s t ru c t u re was no longer needed and the numbers of both
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u n i f o rmed and civilian personnel were reduced. With a

smaller force, infrastru c t u re needs changed, requiring a

reduction in facilities. Pre s s u re was exerted through legislation and budgeting to effect these reductions, including base closure and “realignment.” New approaches to

overall management, including contracting for some

s e rvices previously provided by the military and “privatizing” others, were also introduced throughout the

1990s to address the military ’s changing needs. 

At a DoD historic buildings conference in Annapolis,

Maryland, in July 2000, the Deputy Undersecretary of

Defense for Environmental Security observed: 

The Department [of Defense] has a substantial

property maintenance backlog and a shrinking

DoD maintenance budget. Since 1995, many independent reports have concluded that DoD’s funding

is not sufficient to produce, maintain, and operate

quality housing. In addition, there is a perception

on Capitol Hill that we are not doing enough to cut

costs. Some fear that with over 70,000 additional

structures eligible for historic status over the next

30 years that we will not be able to maintain our

existing inventory without huge budget increases—

increases that many in Congress will never accept.

Our challenge in managing historic properties is to

move beyond compliance—to pursue bolder

resource management initiatives, and to adapt and

reuse historic buildings for other uses. 

The Deputy Undersecretary went on to note: 

In some cases, historic building re q u i rements do

mean higher maintenance costs. In many cases, howe v e r, relevant factors are the size of the building,

d e f e rred maintenance, and sometimes-costly environmental re q u i rements like lead and asbestos

removal. We need to adapt historic re s o u rces to meet

new and innovative functions, and to keep pace with

technological advances. We also need to dispose of

excess real pro p e rt y. Our challenge is to find appropriate adaptive uses for historic buildings, and economical mothballing practices to safeguard them

during interim periods of disuse. We need to incre a s e

the viability of our historic pro p e rties as operational

and economic assets as well as cultural objects.

P re s s u re for additional military base closures and other

operational efficiency measures, as well as accelerated

m o d e rnization of military housing, active training facilities, and other high priority operational facilities (including those proposed to support National Missile Defense

deployment) may be expected in the near future. 

PUBLIC LANDS AND MULTIPLE USES

Bureau of Land Management

The Bureau of Land Management (BLM) within the

D e p a rtment of the Interior manages the largest perc e n t a g e

of public land and associated re s o u rces in the Federal

G o v e rnment. BLM is responsible for 264 million acres of

land—about one-eighth of the land area of the United

States—and about 300 million additional acres of subsurface mineral re s o u rces. BLM is also responsible for wildf i re management and suppression on 388 million acres of

Federal and State lands under interagency agreements, and

works with the military services and other Federal agencies to jointly administer public lands withdrawn for special Federal uses (such as bombing ranges or western

water projects). Most of the lands under BLM management are located in 12 States in the western U.S., including 87.3 million acres in Alaska. An eastern States off i c e

administers small parcels of land and re s e rved subsurf a c e

minerals in States bordering and east of the Mississippi

R i v e r. BLM also maintains the re c o rds of public lands surveys, dating back to the Land Ordinance of 1785, and the

re c o rds of the General Land Office, founded in 1812,

c h ronicling the exploration, surv e y, mapping, and settlement of lands west of the original 13 American colonies.

BLM’s mission direction and its management focus

have evolved considerably over the years, and while it

remains dedicated to “multiple use” of public lands it

has increasingly found itself involved in providing outdoor recreation opportunities for the urbanizing west.

Recently BLM has acquired additional specific responsibilities for managing a number of newly designated

National Monuments—Grand Staircase-Escalante in
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Utah, designated in 1996, and three monuments in

Arizona and California designated in 2000: Agua Fria,

Grand Canyon-Parashant, and California Coastal

National Monuments. 

C u rre n t l y, BLM has approximately 255 listings in the

National Register of Historic Places, encompassing

m o re than 3,610 contributing pro p e rties, 22

National Historic Landmarks, and five Wo r l d

Heritage sites comprising portions of the Chaco

Canyon prehistoric outlier sites in New Mexico. New

National Register listings are being added at a rate of

a p p roximately one per month. Portions of eight

National Historic Trails covering 3,500 miles cro s s

the public lands, while at least 5,000 additional trail

miles occur along 10 other historic trails. Known historic stru c t u res on BLM lands include pre h i s t o r i c

pueblos, cliff dwellings, antelope and bighorn sheep

traps, and agricultural features, as well as historicperiod mining stru c t u res (such as smelters, mill sites,

and charcoal kilns), ranch buildings, adobe fort s ,

stagecoach and Pony Express stops, rail lines and

associated stru c t u res, town sites, lighthouses, cabins,

and Depression-era schoolhouses. 

A p p roximately 228,000 archeological and historic

resources have been recorded on the roughly 13.9 million acres of public lands that have been inventoried for

cultural sites, which is only about 5 percent of all lands

administered by BLM. Conservative estimates of the

number of archeological and historic properties that

may exist on BLM holdings range from four million to

four and a half million.

Responsibilities for BLM’s cultural resources programs

a re spread throughout the field stru c t u re, which

includes State Offices and local Field of District

Offices, as well as a headquarters Cultural Heritage,

Wilderness, Special Areas, and Paleontology Group

under the Assistant Director for Renewable Resources

and Planning. Numerous historic properties are under

active protection, many of them in established BLM

interpretive sites or recreation areas, and many more

are subject to regular patrolling, electronic surveillance,

and other protective measures. 

In Arizona, for example, BLM is responsible for 51

A reas of Critical Environmental Concern covering more

than 800,000 acres; 12 of these areas were designated

l a rgely to protect historic and archeological re s o u rc e s .

The new Agua Fria National Monument north of

Phoenix, Arizona, covers 71,000 acres and contains one

of the most significant collections of late pre h i s t o r i c

re s o u rces in the American Southwest—at least 450 sites

a re known, and there are likely many more in the are a ’s

rugged countryside. The area has long been under BLM

jurisdiction, and much of the management will re m a i n

unchanged. Unlike a National Park Unit, livestock grazing, hunting, fishing, and similar activities will be

allowed to continue, and the 1,440 acres of private

p ro p e rty within the boundaries, or other valid existing

rights such as water rights, will generally not be aff e c ted. However, new mining claims, geothermal leasing,

and off - road vehicle use will be prohibited, and it is

hoped that more funding will be available for re s o u rc e

p rotection, public interpretation, and visitor access.

The situation overall, however, is outlined by BLM:

The BLM manages the largest, most diverse and 

scientifically most important body of cultural

re s o u rces of any federal land managing agency.

H o w e v e r, much of this cultural re s o u rce base is seriously threatened. This “Great Outdoor Museum,”

which has the potential to document the full sweep

of western pre h i s t o ry and history, will soon lack

s u fficient integrity and re p resentativeness to re l a t e

anything more than minor anecdotes.... Natural and

human-cased threats are reducing our opport u n i t i e s

for interpreting sites, for providing long-term access

to pro p e rties valuable to Native Americans and

other ethnic groups, for promoting and facilitating

scientific re s e a rch, and for conserving pro p e rties for

the future. Increasing visitation to the public lands

is resulting in intentional and inadvertent damage

t h rough collection, vandalism, surface disturbance,

and other depreciative behavior. Increasing land use

authorizations for rights-of-way, mining, public

facilities and other legitimate and necessary uses of

the public lands continue to result in an ever- d i m i nishing cultural re s o u rce base. With every year that
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passes, the diversity of our cultural re s o u rces is

reduced, and we lose more of our ability of tell the

s t o ry of the public lands.36 

In the Bureau of Land Management, for example,

“the Bure a u ’s budget has been flat over the last

decade and has seen its workforce decline over this

time period even though its workload has become

m o re complex.” BLM’s operating budget amounts to

$2.82 per acre, compared to $6.65 per acre for the

F o rest Service and $16.85 per acre for the National

Park Service. Similarly, the Forest Service manages 27

p e rcent fewer acres but employs 28 percent more cultural heritage specialists, and NPS manages less than

o n e - t h i rd the acreage of BLM but has more than five

times the number of cultural heritage personnel.

On the plus side, a number of successful projects have

been completed or are underway in Arizona, and provide an idea of the broader range of BLM’s pro g r a m s

t h roughout the West. These include an ongoing cooperative arrangement with the Sierra Club to help BLM

re c o rd prehistoric rock art on its lands; a cooperative

a g reement with the Utah Wing of the Civil Air Patro l

to conduct monitoring flights for protection of cultural re s o u rces north of the Grand Canyon; acquisition

and protection of the Empire Ranch, part of what used

to be one of the largest cattle ranches in the southwest

and home to an adobe ranch house built in 1876; and

management of the early 20th century copper mining

town of Swansea, including use of an Arizona Off

Highway Vehicle Recreation Fund grant to addre s s

public safety hazards and protect and stabilize some of

the remaining stru c t u re s .

BLM plays a major role in Arizona Arc h e o l o g y

Month, one of the most comprehensive public awareness programs of its type in the country. BLM also

p a rticipates in Arizona’s Site Stewards program, a

public-private partnership under the direction and

oversight of the Arizona State Historic Pre s e rv a t i o n

O ffice that supports the work of citizen volunteers to

monitor specific areas or sites and re p o rt incidents of

looting, vandalism, and other destructive action.

H o w e v e r, given the scale and scope of BLM’s 

responsibilities, funding and staffing remain inadequate. Many programs and projects must be pursued

as limited time, money, and personnel re s o u rces permit, and BLM has looked for ways to leverage its

re s o u rces through a variety of partnerships and cooperative ventures. In part this has been reflected in

B L M ’s willingness and ability to work with States,

tribes, local communities, and others. These laudable

e ff o rts need to be supported and sustained thro u g h o u t

BLM. BLM itself has recognized the need for:

■ raising the awareness and understanding of managers and supervisory staff as well as line range

and commodities personnel; 

■ finding ways to achieve more effective integration of cultural re s o u rce considerations in

p roject planning; 

■ taking full advantage of public-private part n e rships (like those outlined above) that may help

BLM meet its stewardship responsibilities more

e fficiently and eff e c t i v e l y ;

■ making priority investments in non-pro j e c t -

driven planning to establish reliable context and

management documents that are responsive to

the values of the resources; 

■ identifying good, replicable models to improve public and tribal involvement to more fully consider

and integrate their concerns and contributions; and 

■ looking for ways to achieve greater parity between

cultural re s o u rce management needs, multiple use

p re s s u res, and other aspects of BLM’s mission.

U.S. Forest Service

The Forest Service, a bureau of the Department of

A g r i c u l t u re, manages 155 National Forests and 20 grasslands on more than 191 million acres of public land, 8.3

p e rcent of the total U.S. land area. More than 85 perc e n t

(163 million acres) is within 12 western states. The

36 “Strategic Paper on Cultural Resources at Risk,” Bureau of Land Management, June 2000.
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F o rest Service manages many congressionally designated

a reas including Wi l d e rness Areas (34.7 million acre s ) ,

National Monument Areas (3.7 million acres), National

R e c reation Areas (2.7 million acres), National Historic

A reas (6,540 acres), National Game Refuges and

Wildlife Pre s e rves (1.2 million acres), National Scenic

R e s e a rch Areas (6,630 acres), and National Wild and

Scenic Rivers (4,348 miles, 95 rivers). The Forest Serv i c e

administers these lands and re s o u rces under the Org a n i c

Administration Act of 1897, the Multiple Use-Sustained

Yield Act of 1960, and the National Forest Management

Act of 1976, in addition to other mandates. 

The Forest Serv i c e ’s principal responsibilities are re f l e c ted in its staff areas: Lands; Wildlife, Fish, and Rare

Plants; Wa t e r, Soil, and Air; Range; Energ y, Minerals,

and Geology; Forest Vegetative Management; and

R e c reation, Heritage, and Wi l d e rness. Responsibilities

for the heritage program are spread throughout the field

s t ru c t u re, beginning with more than 600 ranger districts,

which are the smallest administrative unit of the 250

individual National Forests. 

The National Forests are grouped within nine re g i o n s .

The Federal Pre s e rvation Officer oversees the program from the Washington Office, as part of the

R e c reation, Heritage, and Wi l d e rness Resources staff .

C u rre n t l y, the Forest Service employs appro x i m a t e l y

350 permanent historic re s o u rce professionals, most

of them arc h e o l o g i s t s .

F o rest Service holdings encompasses a significant 

number of historic resources, with a combined total of

more than 277,000 known resources on the roughly 38

million acres that have been inventoried. This represents about 20 percent of all lands administered by the

Forest Service. Conservative estimates of the number of

historic and archeological resources that may exist on

Forest Service lands range from 1 to 1.5 million. 

The Forest Service currently has approximately 900 

listings in the National Register of Historic Places, 15

National Historic Landmarks, and one World Heritage

Site (one of the Chaco Canyon prehistoric outlier sites, at

Chimney Rock, Colorado). As documentation is prep a red, new National Register listings are being added at

a rate of approximately two per month. All of these documented re s o u rces are listed in a variety of inventories

kept at each forest and managed by heritage specialists.

The Forest Service’s annual budget for the Heritage

Program has been about $15 million, less than .4 percent of the total Forest Service budget of $3.4 billion.

Funding reached its height in 1994 at $29.9 million,

and has remained flat for the past six years. The Forest

Service has noted that its limited budget and staffing is

affecting its ability to track and manage its holdings

while lacking basic database capability as well as specific information on the nature, significance, and

appropriate management of historic resources. Its ability to meet recreation, public education, and interpretation demands has been seriously curtailed, as well as

its responsiveness to inappropriate uses, including serious vandalism and looting. As with BLM, road construction, timber harvesting, and other extractive uses

and spin-off effects must all be addressed. 

The Forest Service changed its budget allocation pro c e s s

a few years ago to direct far less to its heritage pro g r a m

overall, but in its place determined to provide monies for

Section 106 compliance for whichever program needs

such compliance. For example, funding for surveys in

p roposed timber sales has typically come through the timber program, and similar needs for fire management

t h rough the national fire plan. This has created a situation where there is very little money allocated directly to

the heritage program for each Region and individual fore s t — c e rtainly not enough to comply with the expectations and re q u i rements of Section 110 of NHPA. In the

mid 1990s, the Sierra Nevada Forests in California developed an archeological and environmental re s o u rces management initiative—the Framework for Arc h e o l o g i c a l

R e s o u rces Management (FARM). The initiative 

is designed to integrate cultural re s o u rce management

into the Forest Serv i c e ’s planning process and overall

management strategy. 

U n f o rt u n a t e l y, since development of the original plans,

the Forest Service has not allocated the money necessary

to implement them, and now the affected forests are
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“ h o rribly out of compliance” with the plans.3 7 This 

situation may change somewhat as both agencies will be

faced with substantial pre s s u res (and additional funding)

to improve land and re s o u rce management, in part

because of recent emergency appropriations in connection with the serious wildland fire emergencies in 2000. 

For the past 10 years, the Forest Service has also tried to

put more emphasis on the Federal responsibility to share

heritage information with the public. “Windows on the

Past” is the umbrella for public programs and pro d u c t s

whose goal is to make heritage sites, knowledge, and

experiences accessible to the public. Windows on the

Past covers a variety of eff o rts, including several national programs as well as numerous local interpretive programs and products, school programs, and community

o u t reach eff o rts. The best known and most successful of

these is Passport in Time, a volunteer program in which

the public assists Forest Service archeologists with

p re s e rvation activities. Archeological excavation, surv e y, historic stru c t u re restoration, archival re s e a rch, and

gathering oral histories have been prominent Passport in

Time projects. The Forest Service has hosted more than

1,200 projects since the pro g r a m ’s inception in 1989.

About 200 to 220 projects a year are undertaken by the

nine Forest Service regions each year. Many of the pro jects are developed in cooperation with universities, local

communities, and other Federal and State agencies. 

A newer program is called Heritage Expeditions and 

is being developed under the Recreation Fee

Demonstration legislation (P.L. 104-134). These are educational tours ranging from archeological excavations,

to rock art restoration, to primitive tool use. Fees fro m

the program are intended to fund protection and continued public access to heritage sites and experiences. The

F o rest Service hosts about 20 Heritage Expeditions each

y e a r, and more could be added in the future .

As with BLM, the Forest Service has been forced to find

c reative ways to integrate its stewardship and other mission needs. For example, the Sears-Kay ruin is a pre h i storic archeological site on the Tonto National Forest just

n o rth of Phoenix, Arizona, which is located along the

G reat We s t e rn Trail, a 3,000 mile-long backcountry, 

o ff-highway vehicle route. Site pre s e rvation, stabilization,

i n t e r p retation, and construction of a picnic area and toilet facility were facilitated by a partnership that included

the Off-Highway Vehicle Fund of the Arizona State Parks

d e p a rtment, the Kactus Kickers Hiking Club of Arizona

Public Service, the Desert Foothills Chapter of the

Arizona Archeological Society, and assistance from a

Federal Bureau of Prisons local inmate work cre w.

The Forest Service is currently updating its Heritage

Resource Management Manual, which is intended to

address all aspects of cultural resource management

from inventory to enhancement and includes direction

on tribal consultation. The manual also includes a collections management policy to guide the agency in its

effort to improve accountability for the management of

artifact collections, and better distinguish Federal from

non-federal holding in museums and other repositories.

The Forest Service employs a full-time Native

American Graves Protection and Repatriation Act

coordinator to assist the agency to meet the requirements for existing collections and human remains, as

well as new and inadvertent discoveries.

New Forest Service manual directions under development will address integration of Section 106 review with

N E PA planning, with the objective of implementing a

m o re comprehensive process that allows for a bro a d e r

assessment of heritage re s o u rces and project impacts.

The Forest Service is also currently developing an

agency-wide computerized data management plan of

which heritage is a part. The National Heritage

Information Management Initiative is working to integrate heritage information at all levels of the agency’s

data management program. It is a daunting task, given

the range of data programs in use at local and regional

Forest Service field offices.

Common Concerns

The most substantial challenges the Forest Service and

the BLM face concern limited staffing and funding 

of these programs compared to the scope of land 

37 Advisory Council on Historic Preservation Historic Preservation Specialist C. Gleichman, personal communication, June 2000.
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holdings, management issues, and the legal requirements that must be met. New policy and internal guidance in both agencies is directed at streamlining individual project reviews so that field specialists may

invest more time in proactive work. While both agencies continue to search for more efficient and effective

ways of meeting their heritage re s p o n s i b i l i t i e s ,

increased demands on public lands, coupled with the

i n c reased complexity of consultation with States,

Indian tribes, and other parties, have increased the time

and effort required to meet Section 106, NAGPRA, and

other review responsibilities, negating much of the time

savings that has accrued through such efforts. 

The vast majority of Forest Service and BLM heritage

assets have no annual maintenance perf o rmed on them.

C u rre n t l y, the Forest Service Heritage Program does not

have the database capability to comply accurately with

D e f e rred Maintenance re q u i rements requested by the

Chief Financial Off i c e r. The approach for 1999 and

2000 has been to develop a strategic framework for

annual re p o rting and identification of priorities with

i n c rementally better data, while developing agency business tools to provide an updated, accurate inventory of

heritage assets and funding needs.38 

Due to limited staffing in relation to workloads, many

field offices have been unable to meet reporting needs

and are falling behind in production of reports for

review and use by planners and others. This is creating

a continuing backlog of evaluations of historic

resources for management purposes. The relatively

common practice of saving time and money by avoiding identified properties through project redesign prior

to evaluating them for National Register eligibility has

contributed to the difficulty of managing resources

whose values remain largely unknown. Funding and

staffing levels have rarely permitted proactive inventories of areas with high potential for significant cultural

properties and evaluations of known, important sites.

During the 1980s, the Forest Service pre p a red many 

f o rest plans to guide management decisions. Those

plans, currently under revision, focus primarily on 

biological re s o u rces, addressing cultural re s o u rces most

f requently in terms of the NHPA Section 106 re s p o n s ibility to consider them in other agency management

actions. It is one of the Forest Serv i c e ’s biggest challenges, echoed by a similar need in the Bureau of Land

Management—to proactively integrate heritage assets in

land management planning eff o rts. 

One of the ways to achieve this goal is to more

effectively integrate NHPA responsibilities into the

e n v i ronmental planning process called for by the

National Environmental Policy Act. Projects and programs that affect land areas such as timber harvest, oil

and gas development, and land exchanges can affect

hundreds of historic resources. Sometimes consideration of those properties under NHPA does not take

place until late in the NEPA decision-making process.

Delaying Section 106 review until specific undertakings

are defined prevents historic resources from being an

effective factor in decision making. 

Staffing and funding constraints have also made it

more difficult to respond to, much less keep up with,

increasing demand for educational and participatory

programs in archeology and history. A 1994 National

Survey on Recreation and the Environment indicates

that visiting nature centers and historic sites were the

two most popular activities on public lands. Further, a

recent publication on volunteer vacations states that

“archeological excavations have more volunteer hours

given to them than any other type of activity.” Still,

while these demands grow, the Federal Government’s

ability to provide those experiences is declining. A good

indicator is the Forest Service’s Passport in Time program: the number of projects has increased from 37 in

1990 to more than 200 in 1999, but the Forest Service

continues to turn away 20 to 25 percent of applicants,

not due to lack of work to be done, but rather to lack

of personnel and budget to organize it.

I n a p p ropriate uses, vandalism, and looting continue to

damage historic re s o u rces on BLM lands and in National

38 Funding made available in the FY 2001 appropriations to address deferred maintenance needs and infrastructure improvement has largely

been earmarked for offices and recreation facilities, not for historic resources.
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F o rests. As re c reation visits, urban and suburban sprawl,

and off - road use increase, vandalism and looting also

i n c rease. Rock art is defaced or removed; significant

a rcheological sites are looted and artifacts scattered or

stolen; burials are disturbed and human remains and

grave items scattered or stolen; and historic period sites

a re scavenged for “collectibles.” Many of these items end

up in local, national, and international black markets. 

In addition to the illegal activity, an increase in visitor

use is taking its toll on protected resources. In short,

many historic resources on public lands are being

“loved to death.” Proactive programs in both education and law enforcement are needed. Programs such as

Passport in Time reduce the amount of inadvertent

damage to cultural sites and increase public awareness

of the need to protect sites, and Site Stewards help track

such damage. However, commercial looting damages

are much greater than that caused by increased use and

visitation. Public education programs help, but cooperation between heritage programs and law enforcement

is needed to pursue cases.

The Society for American Archeology (SAA), 

p a rticipating in discussions as part of the Council

review of public lands management issues at the

Phoenix, Arizona, meeting, has voiced concerns over

policies restricting academic re s e a rch on Federal

lands. There is also a growing concern over control of

access to information and academic freedom, part i c ularly as it relates to the Federal Govern m e n t ’s re s p o nsiveness to tribal concerns and to the conduct of

a rcheological studies on both public lands and tribal

t rust lands. Advances in knowledge, or in ensuring

up-to-date public interpretations of the past, may be

conflicting with ongoing re s o u rce management and

p rotection priorities. SAA has suggested that opport unities for collaboration between Federal agencies and

academic institutions be explored more fully, part i c ularly with re g a rd to scientific re s e a rch that could lead

to better re s o u rce management and public interpre t ation. These are certainly areas that need more attention in the future to ensure that the wide range of 

values and potential public uses re p resented by these 

historic re s o u rces are adequately serv e d .

In summary, public interest in archeology and history,

particularly as it relates to recreation on public lands, is

at an all-time high. Demands for educational and participatory programs increase every year. Use pressures

and illegal activity also increase every year, threatening

the non-renewable cultural resources. Federal land

managers increasingly seek information on past environments and environmental change in order to better

manage current ecosystems and make more informed

management decisions. 

All these demands require increased effort on the part

of agency heritage personnel to first and foremost

know what resources exist and understand their value.

At the end of FY 2000, the Forest Service was in the

process of formally adopting its national strategy,

called “Heritage—It’s About Time!” to set such priorities. BLM was engaged in a similar effort directed at

managerial and budgetary support. 

Without adequate funding, personnel, or baseline

information about resource holdings, it is extremely

difficult to provide land managers with accurate pictures of past land use, to provide opportunities for the

public to gain knowledge of and enjoy heritage sites

and experiences on public land, or even to protect the

significant historic resources and make informed decisions about which ones to protect and invest further

efforts in research and development. 

PARKS, REFUGES, AND SANCTUARIES

National Park Service

The National Park Service in the Department of the

Interior includes 379 units, approximately 83.6 million

acres, ranging from major national parks and monuments, to scenic parkways, preserves, trails, riverways,

seashores, lakeshores, and recreation areas as well as

historic sites and battlefields. 

NPS maintains several inventories of historic resources

within the National Park System. An estimated 26,000

historic and prehistoric structures are included in the

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computerized inventory of all historic and prehistoric

structures having historical, architectural, or engineering significance in which NPS has or plans to acquire

legal interest. The LCS (and related inventories) assists

park managers and technical staff in planning, programming, and recording decisions about appropriate

management and treatment. Condition of these

resources is continually threatened by weather, structural deterioration, erosion, and vandalism, as well as

by other forces, such as fire or visitor use pressures. 

As of the end of FY 1999, data on 24,255 stru c t u re s

had been updated. Approximately 44 percent were

listed in good condition, 40.2 percent in fair condition, 12.2 percent in poor condition, and for 3.6 percent condition was listed as “unknown.” Unfunded

costs for treatments of historic stru c t u res appro v e d

t h rough park planning documents, which were developed with a broad and varied range of public involvement, “currently tops $1 billion.” About 72 perc e n t

of that was for rehabilitation and pre s e rvation costs,

and 17 percent for basic stabilization.

NPS understandably employs the largest number of 

historic re s o u rce specialists in the Federal Govern m e n t .

NPS also has the most extensive and comprehensive policies and technical guidance for managing these

re s o u rces. Detailed management policies apply to

re s o u rces in all units of the National Park System: all

units have long-term general management plans that

u n d e rgo public re v i e w, and most also have more specific

development, land-use, and re s o u rce-specific plans as

well as operating pro c e d u res for maintenance, visitor

s e rvices, and other issues specific to the park or re s o u rc e .

NPS management policies are currently under revision.

They cover a wide range of topics from resource protection and interpretation to facilities management and

visitor services and safety. The Cultural Resourc e

Management guideline for NPS notes that according to

the management policies, 

pending planning decisions, all cultural resources

will be protected and preserved in their existing

conditions.... The National Park Service is steward

of many of America’s most important cultural, natural, and recreational resources. It is charged to

preserve them unimpaired for the enjoyment of

present and future generations. All park management activities stem from these resources. If they

are degraded or lost, so is the essence of the park. 

It goes on to note that:

In reaching decisions about re s o u rce treatment, moreo v e r, pre s e rvation should always receive first consideration. Data re c o v e ry, rehabilitation, restoration, and

re c o n s t ruction may sometimes serve legitimate management purposes. However, these treatments cannot

add to and will likely subtract from the finite material, and sometimes even data sources, remaining fro m

the past. Decisions about them should be based on

a w a reness of long-range pre s e rvation goals and the

i n t e rests and concerns of traditionally associated

g roups.... Internationally accepted historic pre s e rv ation standards continue to stress the protection and

perpetuation of authentic surviving re s o u rc e s .3 9

This does not mean, however, that NPS stewardship is

devoid of contro v e r s y, conflict, or major issues.

Funding availability and deferred maintenance have

long been a concern, and the manner in which priorities are set by park superintendents and others is often

open to criticism.

P rotection and management choices sometimes seem

to pit natural and cultural re s o u rce values against each

o t h e r, or protection of park values against public

access and visitor services. Involvement of outside parties, including elected officials, concessioners and

other business interests, or communities in gateway

a reas with an economic stake in management and use,

is a constant reminder of the many public intere s t s

which the National Park System must addre s s .

M o re o v e r, inholdings, special uses, permitted activities, and leases may also affect park management and

other decisions, both inside and outside park boundaries. Finally, decisions to protect historic re s o u rc e s

39 Cultural Resource Management Guideline (NPS-28), p. 2.
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may also be controversial—witness such recent 

examples as the relocation of the Cape Hatteras lighthouse, various redevelopment plans for Gettysburg

National Military Park, or the imposition of climbing

restrictions on Devil’s Tower in Wyoming (a sacred site

to many Indian tribes). 

A major independent review of the National Park System

and its challenges was released in 1997 by the Natural

R e s o u rces Defense Council and the National Trust for

Historic Pre s e rvation. Entitled Reclaiming Our

Heritage—What We Need to Do to Pre s e rve America’s

National Parks, the re p o rt recommended a wide range of

actions. These recommended actions included:

■ Issuing an Executive order focused on re s o u rce 

p ro t e c t i o n ;

■ Enhancing applied science and ecosystem 

m a n a g e m e n t ;

■ Enlisting the help of gateway communities;

■ Enhancing the visitor experience by establishing

a reservation system for the National Parks;

■ Increasing appropriations;

■ Making Federal transportation funding for all

park transportation systems, not just roads;

■ C reating a new National Park capital impro v ement fund financed through the sale of

National Park Federal agency bonds ensured by

the Federal Govern m e n t ;

■ C reating a new National Park Authority as a

fully guaranteed Federal agency to issue

National Park bonds;

■ Providing assurance that all revenue collected in

the parks stays in the National Park System; 

■ Providing assurance that those who profit from

park resources do more to protect them; and

■ Taking the Land and Water Conservation Fund

off-budget, thus ensuring that its funds will be

spent for the purpose of land acquisition and

state assistance for which the fund was created.

In summary:

What is needed is a comprehensive response to 

the park problems. More money is needed and

mechanisms must be put in place to ensure that the

money that does go to the parks is spent in a way

that protects the parks’ re s o u rces now and for the

f u t u re. In addition, federal, state, and local agencies

must recognize the impact of their decisions on park

re s o u rces and act to protect them. Often what is

happening near the parks is as consequential as what

happens in the parks.4 0

Given funding limitations as well as changing priorities

and a diversity of management philosophies thro u g h o u t

the system, there remains a continuing tension between

p rotection of natural and cultural re s o u rce values in parks,

and between re s o u rce protection and visitor use needs. 

For example, this issue of competing values has arisen at

Elkmont Historic District in the Great Smoky Mountains

National Park in Tennessee and North Carolina; at

Cumberland Island National Seashore in Georgia; in the

Upper Mississippi National River and Recreation Area in

Wisconsin and Minnesota; in Rocky Mountain National

Park in Colorado; and most re c e n t l y, in Yo s e m i t e

National Park in California. 

At Yosemite, for example, the draft Yosemite Valley Plan

analyzes alternatives for achieving NPS’s broad management goals for Yosemite National Park. These goals, as

set forth in the park’s 1980 General Management Plan,

include reclaiming priceless natural beauty; allowing

natural processes to prevail; promoting visitor understanding and enjoyment; and reducing traffic congestion

and crowding. Prior to the plan’s development, NPS

u n d e rtook other planning eff o rts in more specialized

a reas, resulting in a draft Yosemite Valley Housing Plan,

draft Yosemite Valley Implementation Plan, and

Yosemite Lodge Development Concept Plan. Some

o rganizations and members of the public objected, howe v e r, to this segregated approach to planning in the park,

and thus each of these plans were incorporated into the

c u rrent draft Yosemite Valley Plan. 

Prior to the development of the draft plan, NPS, the

California SHPO, and the Council entered into a

Programmatic Agreement in 1999 for the operation

40 Reclaiming Our Heritage, July 1997, pp. viii-x.
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and maintenance of the park. The park’s Section 106

responsibilities for the draft plan therefore are being

addressed in accordance with the terms of the PA.

Because the plan’s preferred alternative would adversely affect historic properties, NPS must consult with the

California SHPO and the Council. The PA would allow

use of standard mitigating measures to address the

adverse effects, but the California SHPO must first

agree to their use following consultation. 

In July 2000, the Council provided NPS with initial

comments on the draft Yosemite Valley Plan. Although

the plan identifies the protection of both natural and

cultural resources as a priority, the Council voiced concern over an apparent emphasis on natural resource

restoration over the protection of some important historic properties. For example, the preferred alternative

includes the removal of the historic superintendent’s

house in order to re s t o re area natural re s o u rc e s ,

removal of four historic bridges to restore the natural

flow of the Merced River, and removal of 277 tent cabins that comprise the most significant and last remaining complex of this type of structure in the National

Park System. Other historic preservation organizations,

including the National Trust for Historic Preservation,

raised similar concerns about the proposed plan. 

NPS met with the California SHPO to discuss possible

refinements to the plan that would better address conc e rns about treatment of historic pro p e rties in the

Yosemite Va l l e y. NPS subsequently responded thoughtfully and fully to the Council’s comments, and agreed to

modify or reconsider several of the proposed actions that

would more fully protect historic re s o u rce values. The

historic superintendent’s house would be relocated; only

one bridge will be removed and the re m o v a l ’s effects on

s t ream flow studied further; and a re p resentative sample

of tent cabins would be retained. Adaptive reuse of other

historic stru c t u res will also be considered. 

The draft Yosemite Valley Plan illustrates the often

competing interests of protecting and preserving both

natural and cultural resources in national parks. There

is a great deal of public interest in preserving both

kinds of resources; in fact, the entire Yosemite Valley is

c o n s i d e red a cultural landscape with both natural and

cultural re s o u rces contributing to its significance. In

addition, the Merced River is designated a “Wild and

Scenic River” under the Wild and Scenic Rivers Act. This

designation may affect how historic pro p e rties located in

the river corr i d o r, including archeological sites and eight

historic bridges, are managed in the future. 

In an effort to offer advice on the overall issues 

embodied in such tradeoffs, The Council has formed a

task force to examine questions of balancing cultural

and natural values in National Parks. The hope is that

its findings and recommendations may ultimately be

useful not only to the National Park Service but to

other agencies facing similar dilemmas.

In order to begin to address long-term funding, 

maintenance, and related concerns, a demonstration program was begun in FY 1998 on a regional basis that is

called “Vanishing Tre a s u res.” Intended to be used in

National Park units in the arid West, it has three primary

objectives. First, it focuses funding on emergency pro j e c t

needs where prehistoric and historic stru c t u res are in

immediate, imminent danger due to natural deterioration

and visitor use pre s s u res. Second, it focuses on training

and support for personnel with expertise in historic stru ct u res stabilization and restoration, and the transmission

of crafts skills from aging specialists nearing re t i re m e n t .

T h i rd, it promotes sustainability by slowly moving fro m

an emergency mode to a continuing, in-place pro g r a m

that can meet these needs in the future, reduce the backlog of maintenance projects, and support a systematic

a p p roach to agency stewardship for these re s o u rce types. 

Including base increases for personnel in selected parks,

as well as small amounts for program administration

and training of personnel, the authorized budget was

$1 million in FY 1998, $1.987 million in FY 1999, and

$2.981 million in FY 2000. Mesa Verde National Park,

for example, after years of trying to obtain much needed funds for ruins stabilization through cultural

resources channels, has finally received some muchneeded assistance through capital improvement allocations. More recently, the park received grant funds to

stabilize the cliff dwellings, and to hire permanent staff.
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NPS has also begun developing a broader national 

initiative known as the “Cultural Resource Challenge”

to increase understanding and budgetary support for

cultural resources in the parks. Modeled after a similar

successful campaign to address natural resource issues,

the initiative is currently in draft and has identified the

following priorities: 

Research and Knowledge—NPS must have credible

research, documentation, and information in order to

do the best job of preserving and interpreting our

Nation’s past.

Planning—The American people expect their historic

places to be preserved for them in the most efficient,

informed, and comprehensive manner.

E d u c a t i o n—Americans want to understand their

shared history; NPS must address their needs in the

most effective way.

Preservation and Maintenance —NPS must have the

best tools and adequate resources to do the job.

O rganization and Par t n e r s h i p s— P re s e rving our

Nation’s past is everyone’s responsibility; the Federal

Government is one of many.

4 1

The draft action plan outlines priorities for budget and

p rogram initiatives to advance these goals over the next

five years, but it is unclear if comprehensive support for

the plan will be included in the FY 2002 budget. Early

i n f o rmation indicates that at a minimum, the Bush

Administration will be supporting funding to begin to

a d d ress the widespread maintenance backlog thro u g h o u t

the National Park System. 

A second initiative NPS recently launched in cooperation with the National Park Foundation, is not directed at cultural heritage alone, but could have a major

impact on use and appreciation of such resources.

Known informally as “the message project,” it is aimed

at promoting the National Park System and bolstering

public understanding, enjoyment, use, and attendance.

Marketed as “Experience Your America—365 Days,

379 Ways,” it includes a public advertising campaign

and promotion of a new National Parks Pass for $50

per year to cover entry to park units that charge a fee.

What is not clear is how this initiative fits in with NPS

plans to address overcrowding and use pressures in

some parks, and whether the campaign will aggressively promote lesser-known and underused park units to

try to help correct this imbalance.

U.S. Fish and Wildlife Service

The U.S. Fish and Wildlife Service (FWS) of the

D e p a rtment of the Interior is responsible for 521

National Wildlife Refuges as well as other facilities on 93

million acres. While principally re g a rded as a pro t e c t o r

of biota and natural re s o u rces, FWS has a cultural

re s o u rce management program, a Federal Pre s e rv a t i o n

O ff i c e r, and some extremely important historic

re s o u rces. FWS has documented more than 11,000

a rcheological and historic sites on a small percentage of

its lands, and estimates that it is responsible for tens of

thousands of additional sites yet to be identified. 

Cultural properties range in age and type from the Sod

House historic ranch on the Malheur National Wildlife

Refuge in Oregon, to early 20th-century military fortifications in Fort Dade on Egmont Key National

Wildlife Refuge in Florida. They also include a 10,000-

year-old site on a refuge in Tennessee, a segment of the

Lewis and Clark National Historic Trail on the Charles

M. Russell National Wildlife Refuge in Montana, and

Victorian-era historic buildings on the DC Booth

Historic Fish Hatchery in South Dakota. In FY 2000,

Congress and the Secretary of the Interior designated

the Battle of Midway National Memorial in the Pacific,

to be managed by FWS as part of the Midway Atoll

National Wildlife Refuge.

H o w e v e r, FWS only has about 20 specialized employees

nationwide to deal with historic re s o u rce management

issues on FWS’s vast holdings, many of which are not

managed passively but modified to improve wildlife

habitat and breeding grounds. It sometimes appears that

FWS in general is unaware that it does have such

41 “Cultural Resources Challenge—The National Park Service’s Action Plan for Preserving Cultural Resources,” draft, September 2000.
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re s o u rces or does little to manage these heritage assets. In

other cases, refuge managers and local community

o rganizations are taking an active role in both pro t e c t i o n

and successful public interpre t a t i o n .

An Executive order signed in 1996 sets new dire c t i o n

for FWS’s Refuge System as it approaches its centennial in 2003. For the first time, a conservation mission

has been designed for the Refuge System “to pre s e rv e

a national network of lands and waters for the conservation and management of the fish, wildlife, and

plants of the United States for the benefit of pre s e n t

and future generations.” 

The Executive order goes on to define six compatible

wildlife-dependent recreational activities (hunting, fishing, wildlife observation, photography, environmental

education, and interpretation) as priority uses of the

Refuge System, and directs the Secretary to provide

expanded opportunities for these activities. It defines

four guiding principles for management of the Refuge

System: habitat conservation, public use, partnerships,

and public involvement. It also directs the Secretary, in

carrying out his trustee and stewardship responsibilities, to undertake actions in support of management

and public use of the Refuge System. 

In some ways, FWS has been overlooked by many

within as well as outside of the Federal Govern m e n t ,

and its stewardship of historic re s o u rces has not been

subjected to a great deal of scru t i n y. It has been

assumed, perhaps incorre c t l y, that most of the agency’s

activities are benign or involve passive management of

the refuge system, although clearly there is a wide variety of actions ranging from physical habitat impro v ement, to road, re s e a rch station, and visitor center cons t ruction, to public access of various kinds. Pre s s u re s

for new energy development and similar re s o u rce uses

may be expected within some refuges. The public does

not have a broad understanding and appreciation of

FWS or its historic re s o u rce activities, but the agency’s

newly defined mission and upcoming anniversary

might both offer opportunities to enhance aware n e s s

and a more proactive stewardship of its historic

re s o u rce holdings.

National Oceanic and 

Atmospheric Administration

The National Oceanic and Atmospheric Administration

(NOAA) of the Department of Commerce, which includes

the National Weather Service, manages 10 Marine

Sanctuaries and several estuarine sanctuaries amounting

to about 6.7 million acres of submerged lands and wetlands. Many marine sanctuaries and coastal areas contain

historic shipwrecks and other kinds of archeological sites,

and the wreck of the Civil War ironclad USS M o n i t o r i n

the M o n i t o r National Marine Sanctuary off the coast of

N o rth Carolina is a National Historic Landmark. 

NOAA has or is in the process of developing 

management plans for its 12 current National Marine

Sanctuaries, and these plans include sections on dealing

with historic re s o u rces. NOAA also manages a number of

National Estuarine Research Reserves in conjunction

with various State Governments. As with other parks and

refuges, there are increasing pre s s u res from the general

public as well as academic institutions for access and a

variety of re s e a rch and other uses in these sanctuaries. 

Common Concerns

Two major issues face the National Park Service and

related agencies as they attempt to meet their historic

re s o u rce stewardship responsibilities. First, balancing

p rotection of natural re s o u rces and values with care of

historic and cultural re s o u rces is not a straightforw a rd

task. Funding priorities and competition for scarc e

money and hiring of technical experts are clearly factors.

A second and related concern is agencies’ ability to provide sufficient visitor access and services for ensuring

public use and enjoyment without impairing the values

for the park, refuge, or sanctuary. In the large natural

parks and the refuges and sanctuaries, historic re s o u rc e s

often play a decidely secondary role in management as

well as funding decisions, even though they may figure

p rominently in visitor use and services, provide employee

housing and administrative facilities, and offer cre a t i v e

o p p o rtunities for public interpretation. 

The social, economic, and political pre s s u res for 

competing needs, uses, and priorities are many. Local

communities rely on parks and similar areas for the
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related employment opportunities they bring as well as

the other economic development they attract. At the

same time, local residents and user groups often chafe

at the loss of tax revenues due to public ownership of

park lands, raise concerns about access limits, or balk

at other restrictions. More cooperative efforts with

community-based organizations, “friends” groups, and

State, tribal, and local governments need to be explored

to help deal with these and similar issues. 

PUBLIC WORKS AND INFRASTRUCTURE

Many of the major public works and a great deal of

the infrastru c t u re for interstate commerce and transp o rtation, energy production, and flood control were

originally constructed as Federal projects. During the

New Deal period of the 1930s and 1940s, Federal

agencies like the U.S. Army Corps of Engineers, the

B u reau of Reclamation, the Tennessee Va l l e y

A u t h o r i t y, and the regional power administrations

(Bonneville, We s t e rn Area, Southwestern, and

S o u t h e a s t e rn) became associated with the development of major navigation systems, water control, and

power generation, and spearheaded such public 

p rojects along with New Deal agencies like the 

Works Pro g ress Administration and the Civilian

C o n s e rvation Corps. 

Following World War II, highway construction and

expanding air service found Federal support through the

B u reau of Public Roads and the Civil Aviation Agency,

which eventually became the Federal Highway

Administration and the Federal Aviation Administration

in the newly formed Department of Tr a n s p o rtation 

during the 1960s. 

Many of these programs now receive Federal 

assistance as State and local projects, but a number of

major public works remain in Federal hands. The

D e p a rtment of Tr a n s p o rtation retains management

responsibility for historic re s o u rces such as Union

Station in Washington, DC, as well as Federal Av i a t i o n

Administration air traffic control and other facilities at

many of the Nation’s airports. 

U.S. Army Corps of Engineers

The U.S. Army Corps of Engineers manages 459 lakes

and other re s o u rces with a combined total of 11.7 million

a c res of land and water under its jurisdiction, and Corps

p rojects provide more than 30 percent of re c re a t i o n a l

o p p o rtunities on Federal lands. With 41 districts in eight

divisions, and several re s e a rch, development, and training

centers, the Corps is one of the most experienced Federal

agencies in dealing with historic re s o u rces. It also has one

of the larger agency staffs, with cultural re s o u rce specialists in most district offices. The Corps runs an

E n v i ronmental Laboratory, an Engineering and Support

C e n t e r, and a Construction Engineering Researc h

L a b o r a t o ry, and several Corps districts have established

centers of expertise (in Seattle and St. Louis, for example)

for historic re s o u rce stewardship work.

Unfortunately, the Corps is also currently under a great

deal of internal and external scrutiny because of recent

activities and responsiveness to executive and congressional directives and oversight. Media reports, too,

have been extremely critical of Corps actions and command decisions. While the Council did not focus a

great deal of time and attention on these agencies and

their holdings during the course of this study, it is clear

that some scrutiny is necessary.

Tennessee Valley Authority and 

Bureau of Reclamation

Other agencies need financial attention. The Tennessee

Valley Authority, for example, ceased to receive a

Federal appropriation in FY 2000 for its activities.

While still operating as a Government corporation, and

still responsible for several hundred thousand acres of

land and miles of reservoir and riverine shoreline, it

must manage these resources only with funds from

electric power ratepayers in the Tennessee Valley system. Formed as a New Deal entity in 1933 to develop

the Tennessee Valley area, it retains important archeological holdings, sites of traditional cultural value to

the Cherokee and other Eastern Indian tribes, and

resources from the settlement history of the nation’s

fifth largest river system. In addition, many of

Tennessee Valley Authority’s dams, power plants, and

other facilities are themselves historic resources worthy
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of attention and preservation consideration. It has only

six staff members to address the special stewardship

needs of these resources. 

An examination of the Strategic Plan pre p a red by the

Tennessee Valley Authority is instructive. Now a Federal

corporation that no longer receives a Federal appro p r i ation, TVA’s plan is actually more supportive of stewardship needs than plans from many other agencies. Tw o

strategic goals in the plan seem to bear on steward s h i p

issues: Goal 3, “Manage the natural re s o u rces of the

Tennessee Valley region in an environmentally sustainable manner,” and Goal 4, “Maintain the value of federal assets entrusted to TVA, while supporting their wise

use by and for the public in support of TVA’s mission.” 

U n f o rt u n a t e l y, the implementing strategies are 

incomplete. Strategy 3.C. focuses on “managing re s e rvoir lands to protect cultural re s o u rces, reduce ero s i o n ,

and provide wildlife habitat, but the perf o rmance measu red is “critically eroded sites stabilized.” Strategy 4.B.

d i rects managers to “support public uses of federal

assets under TVA management that are consistent with

s t a t u t o ry responsibilities while protecting the value of

those assets for the future,” but perf o rmance is to be

m e a s u red by “re s e rvoirs with completed compre h e n s i v e

re s e rvoir land plans.”4 2

Nowhere is there explicit recognition of the historic

value of TVA dams and power generation facilities, or

of the recreation or regional tourism value of historic

resources on TVA lands. At the same time, interviews

with TVA staff indicate that historic inform a t i o n

included in reservoir land plans is minimal, and more

comprehensive studies and resource evaluations have

been curtailed due to lack of staff and funding.

Over the last several years, the Bureau of Reclamation

(BoR) in the Department of the Interior has been under

similar pressures. It is the Nation’s second largest

power producer, after the Tennessee Valley Authority.

BoR has gone through considerable downsizing and

reorganization, and must manage resources on millions

of acres of lands withdrawn for project purposes from

other public lands. At the same time it must continue to

provide water for one out of every five western farmers

(who produce 60 percent of America’s vegetables and

25 percent of its fruit and nuts), as well as for the

increasingly developing urban areas of the arid West.

R e c reation on BoR projects becomes incre a s i n g l y

important each year as well.

Many of BoR’s dams, canals, hydropower generating

stations, and other facilities are historic resources, and

four are National Historic Landmarks. The historic

Roosevelt Dam on the Salt River near Phoenix,

Arizona, was de-designated in 1999, however, and

three of the remaining National Historic Landmarks

are included by the National Park Service on its watch

list of threatened landmarks. Indian tribes have major

interests in BoR project lands, and have been increasingly involved in discussions affecting those interests,

such as the changes in the operation of the Glen

Canyon dam in portions of the Colorado River/Grand

Canyon system. 

Other signs of strain are showing. As reported by 

the Bureau of Reclamation in its strategic plan, 

“A Department-wide Inspector General’s audit found

deficiencies in managing artwork and artifacts within

the bureaus and identified management of Museum

Property as a Material Weakness under the Federal

Manager’s Financial Integrity Act. To address this

issue, we and all other bureaus will catalog their museum properties, cultural resources, and artifacts and

p rovide input into the Depart m e n t ’s Annual

Performance Plans.”4 3

Common Concerns

The public works agencies, and in particular the U.S.

Army Corps of Engineers, deserve specialized attention

beyond the scope of this study. They have substantial

resource holdings, many of which are historic dams

and navigation facilities that are complex and costly to

42 Government Performance and Results Act Strategic Plan, FY1997-2002, Tennessee Valley Authority, September 30, 1997. 

43 Strategic Plan 2000-2005, Bureau of Reclamation, draft, October 22, 1999.
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maintain and manage. They also administer large tracts

of project lands that are managed for recreation and

other related uses. All are under budgetary and staffing

pressures. As expressed by BoR’s preservation officer:

As the agency’s budget shrinks, so does pro g r a m

accomplishment and the ability to keep staff at a

number sufficient to meet program re q u i re m e n t s .

This is particularly true as construction related activities are reduced. At the same time that

R e c l a m a t i o n ’s budget is in decline, new unfunded

mandates are placed upon offices.... However,

Reclamation has not fully embraced the financial

re q u i rements for a healthy cultural re s o u rce management program, including historic pre s e rv a t i o n

planning, Section 110 surveys and related Section

106 compliance, heritage education, museum pro pe rty management, and NAGPRA compliance. The

agency must identify and maintain professional cultural re s o u rce management staff at levels that meet

annual program management goals.4 4

Focused discussions with these agencies should seek to

identify the most cost-effective and efficient ways to

maintain their historic re s o u rce programs within the

context of their specialized missions, privatization,

and re o rganization. 

AREAS OF INTEREST 

TO NATIVE AMERICANS

In the last decade, most Federal agencies have 

established formal policies for consulting with Indian

tribes, in keeping with both their statutory and

Executive order obligations as well as long-standing

t reaty and trust responsibilities. Emphasis on tribal

s o v e reignty and self-determination have incre a s i n g l y

contributed to Federal Government relations with

tribes. More o v e r, under NHPA and other statutes,

Native Hawaiian Organizations have also been singled out for enhanced roles in consultation on issues

of interest and concern to them, as have Native

Alaskans under more specialized legislation like the

Alaska Native Claims Settlement Act. 

Most Federal land managing agencies have created

positions or offices for liaison with Indian tribes, and

several of the agencies with holdings or activities in

Hawaii have identified Native Hawaiian liaison as a

priority in their organizations. 

During the course of its meetings in New Mexico and

Hawaii, members of the Council met with representatives of the Pueblo of Jemez as well as Native

Hawaiians from several organizations and community

groups. The views expressed in each of these meetings

provided insight into the interests and concerns of both

Indian tribes and Native Hawaiians regarding preservation of traditional lifeways and historic places as well

as the Federal Government’s responsiveness. 

Indian tribes have become more involved in 

consultations regarding Federal undertakings subject to

Section 106 of NHPA, and in Federal land management

decisions. The 1992 amendments to NHPA establish

that properties of traditional religious and cultural significance to Indian tribes and Native Hawaiian organizations may be eligible for inclusion in the National

Register. This sometimes involves the identification of

very large geographic areas, or landscapes, of traditional cultural and religious significance to Indian

tribes and Native American practitioners. 

Large land areas proposed as National Register-eligible

districts include geographically distinguishable areas

such as the 17,284 acre Yamsay Mountain Cultural

Landscape in south central Oregon, a place of spiritual

significance to the Klamath Tribes, and the Zuni Salt

Lake in west-central New Mexico, which was recently

expanded to include a buffer zone of 182,000 acres of

land. The National Register-eligible Medicine Lake

Area Traditional Cultural Property (TCP) District of

northern California (23,650 acres) comprises 21 individual TCPs within and close to a volcanic caldera

important to several tribes for religious activities. 

44 Bureau of Reclamation Federal Preservation Officer’s Memorandum to Executive Director, Advisory Council on 

Historic Preservation, November 15, 1999.
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S i m i l a r l y, the summit cluster of Mauna Kea on the island

of Hawaii has recently been determined to be eligible for

the National Register as a historic district for its traditional and religious significance to Native Hawaiians. The district includes many features that are historically, culturally,

and visually linked and remain important to pre s e n t - d a y

practitioners. Future decisions about this area and its use,

home to an array of telescopes and other scientific facilities

s u p p o rted in part by the National Aeronautics and Space

Administration, are embroiled in contro v e r s y. 

Traditional cultural landscapes such as these offer new

challenges to Federal land managing agencies, who are

used to working with a variety of user groups, but not

necessarily Native Americans. Federal agencies are now

being forced to examine their land management decisions through a diff e rent cultural lens, that of Native

American traditional culture, and to understand the differing values these groups ascribe to lands that have traditionally been managed for public re c reation, grazing,

and re s o u rce extraction. 

Increasingly, and often with strong opposition from

other groups, the participation of Indian tribes in the

decision-making process results in decisions that shift

land uses to better accommodate traditional cultural

practices. For example, after substantial controversy

and pressure from a coalition of tribal groups and traditional practitioners, Bighorn National Fore s t ,

Wyoming, has developed a Historic Preservation Plan

for the protection of sites within an 18,000-acre area

surrounding the Bighorn Medicine Wheel, a Native

American TCP and National Historic Landmark. 

Indian tribes view the Federal Govern m e n t ’s steward s h i p

responsibilities in the broader context of the trust re l ationship between the Federal Government and Indian

tribes: through treaty rights, and the re q u i rement for

g o v e rn m e n t - t o - g o v e rnment consultation with Federally

recognized Indian tribes. The relationship between the

Federal Government and Indian tribes is based on the

s o v e reign status of tribal governments and, thus, is very

d i ff e rent from the Govern m e n t ’s relationship with

Native Hawaiian organizations. However, Indian tribes

and Native Hawaiians often want to be actively involved

in Federal land management decisions, and to be conside red partners or co-managers of lands within their traditional homelands. The challenge to Federal agencies is to

balance the needs and desires of re c reationists, perm i ttees, and re s o u rce user groups with the protection 

of these traditional cultural landscapes and the needs of

traditional practitioners.

Jemez Pueblo, New Mexico

The Pueblo of Jemez, New Mexico, in an area rich in

a rcheological and historic sites noted for its attraction to tourism, has an important relationship with

its Federal land management neighbors. The tribe has

just over 3,000 members, most of whom live in the

sole remaining village and the immediate vicinity.

R e s e rvation trust lands total about 90,000 acres, 

but the Pueblo recognizes a much larger area as its

traditional homeland. 

The Forest Service, the National Park Service, the Bure a u

of Land Management, and the Department of Energy all

manage and control re s o u rces of traditional interest to

the Jemez people, and the tribal Department of

A rcheology and Historic Pre s e rvation has cooperated

actively with these agencies, especially with the Fore s t

S e rvice, on identification and evaluation studies as well as

p rotection of many of these sites. These include 62 major

ancestral village sites, some very large, and 12,000

re c o rded sites in the tribe’s database. One known arc h e ological site contains the remains of more than 3,000

rooms. Sophisticated Geographic Information Systems

and Global Positioning Systems as well as other re m o t e

sensing and computerized data re c o rding and analysis

techniques are being used to help identify these sites, with

re s e a rch organizations underwriting much of the cost. 

The tribe also has historic relationships to far distant 

cultural areas in southwestern Colorado and west-central

New Mexico, and is pursuing various claims for re p a t r i ation of human remains and cultural items taken fro m

Federal lands in these areas. 

The tribe has major concerns about management of and

public (as well as commercial) access to these sites, particularly off tribal lands, and is pursuing eff o rts to forg e
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management partnerships that permit some access and

i n t e r p retation when properly balanced with public education as well as training for Federal employees. It is also

attempting to negotiate with Federal land managers over

what it deems adequate protection and restriction of

public access to areas containing sacred sites.

U n f o rt u n a t e l y, the tribe has been hampered in these

e ff o rts by public disclosure and freedom of inform a t i o n

requests, turnover of responsible Federal officials, and

academic concerns over re s e a rch access. Conflicts over

intellectual pro p e rty rights and the public’s Aright to

know” have begun, and promise to grow in the future .

For example, as the Jemez note in a tribal fact sheet:

A few popular misconceptions re g a rding the

Pueblo of Jemez exist in the published literature.

For example, the name “Jemez” does not mean

“mirage people” or “people of the canyon.”

Likewise, the name “Walatowa” [the name of the

main village] does translate to “village of the bear.”

The true definition of these words constitute intellectual property that the Tribal Leaders choose not

to share with those of the outside world.

Medicine Lake, California

The Forest Service and Bureau of Land Management

concluded consultation in June 2000 with Indian tribes

regarding the proposed construction of two geothermal

projects in the Medicine Lake Highlands in northern

California. These would be the first of a series of geothermal developments proposed for Highlands. The

projects involved the construction of well fields, power

plant facilities, and transmission lines on Forest Service

lands. BLM issued leases for both projects in the 1980s

before it realized the extent of Native American interest in this geographic area or the historic significance

ascribed to the area by Indian tribes whose traditional

territory included the Highlands. 

One Indian tribe and many traditional practitioners

from other tribes opposed any industrial development

in the Medicine Lake Highlands, fearing that the noise

and increased activity in the area, and the visual intrusion of steam plumes and large transmission lines

would deter traditional cultural use of the area. 

In addition, traditional practitioners expressed a 

genuine concern that geothermal development in the

area would diminish the spiritual power of the area. 

Consultation to resolve the effects of the proposed

developments on the Medicine Lake Area traditional

cultural properties district and other historic properties, carried out pursuant to Section 106 of NHPA, represented a clash in cultural perspectives. The Federal

agencies and developers saw a vast area of untapped

energy resources with little observable traditional use.

Traditional practioners were hesitant to divulge the

extent and locations of their religious activities. From

the Native American perspective, the introduction of

even one power plant would significantly alter the quiet

and relative seclusion of the Highlands and open the

door to unlimited industrial expansion. 

Despite these disparate perspectives, consultation 

concluded in an agreement to deny approval of one

project, located within the Medicine Lake Area TCP

District, and impose strict monitoring and mitigation

for the approved development. The agreement reached

required the Forest Service to work in partnership with

several northern California Indian tribes to develop a

Historic Pro p e rties Management Program for the

Medicine Lake Highlands; to assess the need to amend

its land and resource management plans to better protect the traditional cultural values of the area; and to

minimize auditory and visual impacts of the project on

traditional use and the natural environment. 

The agreement did not satisfy all parties: tribal 

representatives opposed to geothermal development

and Calenergy, the developer for the denied project,

were disappointed at this outcome, but the solution

represented a good faith effort on the part of the

Federal agencies to accommodate Native American

concerns into their present and future land management decisions. It also demonstrates that despite an

inauspicious beginning, with highly polarized views on

the appropriate management of the Highlands, it is

possible through consultation with the affected parties

to integrate traditional Native American perspectives

into management decisions affecting large land areas. 
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Devil’s Tower, Wyoming

When Federal agencies propose to manage traditional

cultural landscapes in a manner that protects traditional

cultural and religious practices and beliefs, they often

meet considerable resistance from re c reationalists or

c o m m e rcial outfitters who, until re c e n t l y, have enjoyed

u n restricted use of an area. When a TCP is also a sacre d

site, agencies face even greater challenges, because of

lawsuits raising the free exercise and establishment

clause of the first amendment to the Constitution. 

For example, at Devil’s Tower National Monument,

Wyoming, the interests of rock climbers clashed with

the American Indian’s re v e rence of the landform

known as Devil’s Tower. The first site to be declared a

National Monument (under the Antiquities Act) by an

American President, Devil’s Tower is a property of

tremendous religious and cultural value to Indian tribes

that in the past inhabited northeastern Wyoming. In

seeking to balance the cultural preservation needs of

tribes with the legal and economic interests of EuroAmerican rock climbers who view the tower as a

world-class site for technical climbing, the National

Park Service in 1995 issued a climbing management

plan calling for a moratorium on climbing during June

each year, the busiest climbing month at the tower.

Despite a high success rate for voluntary compliance with

the closure, NPS was sued by an organization re p re s e n t i n g

c o m m e rcial climbing outfitters who argued that the clos u re was an impermissible establishment of Indian re l i g i o n

by NPS.4 5 Although NPS prevailed in the 10th Circ u i t

C o u rt of Appeals, this and other recent lawsuits have created some reluctance among Federal agencies to pro h i b i t

or restrict re c reational activities to protect the ability of

Native Americans to engage in religious activities at TCPs. 

Hawaii and Native Hawaiian Organizations

The issues of concern to Native Hawaiians regarding

Federal stewardship are very similar to those of Indian

tribes and were discussed at the spring 1999 Council

meeting in Honolulu, Hawaii. Council members met

with Native Hawaiian representatives to learn about

Hawaiian culture and practices and how they influence

cultural resource management decisions. 

As illustrated over the course of the meeting, Native

Hawaiians define “historic pro p e rties” and “consultation” within their own cultural context. Overall, connections between the natural, cultural, and spiritual landscape, including traditional and continuing use of historic

places and re s o u rces, must be considered in Federal

agency planning. In essence, there is no distinction

between the natural, cultural, and spiritual aspects of a

landscape that includes flora, fauna, natural feature s ,

viewsheds, and intangibles. 

The challenges of managing such a landscape were also

discussed by Council members, representatives from

the Army, and the surrounding Native Hawaiian communities at the Makua Military Reservation (MMR).

MMR encompasses Makua Valley on the Waianae

coast on the island of Oahu. Makua means “parents,”

a place where the earth mother and sky father meet.

Not only is the entire coastline from Makua to Kaena

Point a sacred place but it was, and still is, home to

many communities. 

MMR is the largest training area on Oahu that 

supports both maneuver and live training. The Army

took over the entire Makua-Kaena Point in 1941 after

the bombing of Pearl Harbor, but the valley was home

to limited military use since the 1920s. Intensive joint

service and Army training activities including ground

maneuvers, amphibious landings, naval and air bombardment, helicopter strafing, and mortar and artillery

f i re have been conducted at MMR for decades.

Military occupation and training activities have precluded access to cultural and religious properties and

caused extensive damage to historic sites.

Makua Valley stretches from a moderately high ridge line

to the ocean. The valley is approximately 4,000 acres and

includes caves, terraces, forests, and beaches. It embodies

many of the concepts and values of Hawaiian culture

both in legend and in current practices and beliefs. It also

45 “Bear’s Lodge or Devils Tower: Intercultural Relations, Legal Pluralism, and the Management of Sacred Sites on Public Lands,” 

Lloyd Burton and David Ruppert, Cornell Journal of Law and Public Policy Vol. 8, No. 2, 1999. 
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contains physical evidence of a thriving lifeway, with

heiaus, platforms, walls, habitation sites, agricultural terraces, shrines, caves, and imu ovens. One of the sites,

Ukanipo Heiau, is listed in the National Register. 

The Army has recently implemented Integrated

Training Area Management, a land management program to integrate Army training and other mission

requirements for land use with sound natural resource

principles, at MMR. Under this program, the Army has

begun conducting revegetation projects at Makua to

strengthen the environment and provide a more realistic training environment. It has also suspended training

to evaluate its fire management strategies and training

activities. The Army has proposed to limit the types of

weapons it uses in Makua as well as prohibiting other,

more destructive weapons and ammunition. The current proposal also acknowledges that Makua is a place

of importance in Hawaiian history.

The Army has also taken a positive step towards 

involving the Native Hawaiian community in its management of Makua Va l l e y. In 1998, the Army began a

p rocess to establish a cooperative program with the

Native Hawaiian community on the Waianae Coast and

the State of Hawaii (which also owns some land along

the coast). The program opened Ukanipo Heiau to re l igious practitioners under the American Indian Religious

F reedom Act, and helped establish an advisory council to

develop appropriate protocols, act as curators, and to

make recommendations about rehabilitation and pre s e rvation for the site. The Army works cooperatively with

the advisory council on other management issues such as

site protection, fire prevention, and ordnance re m o v a l .

The Army and the community maintain liaison positions

to facilitate the cooperative program and ensure timely

and effective communication.

Native Hawaiian re p resentatives also discussed with

Council members concerns re g a rding consultation by

other Federal agencies and confidentiality of inform a t i o n .

The oral nature of Hawaiian culture can make it diff i c u l t

for Native Hawaiians to participate fully in Federal planning and review processes that rely on written documentation and communication. Native Hawaiians may also

be unwilling to share certain information with Federal

o fficials because of prohibitions or concerns that such

i n f o rmation may be publicly disclosed. Finally, the larg e

number of Native Hawaiian organizations and the lack

of a governmental status and stru c t u re for these org a n izations has been viewed by Federal agencies as a barr i e r

to consultation. 

In response, the Council members voted to write to

Federal agencies to encourage them to establish liaisons

with Native Hawaiian organizations to facilitate consultation. The Council subsequently received positive re s p o n ses from several agencies, including the National Park

S e rvice and the Department of Agriculture, indicating that

they either had liaisons in place or were willing to establish such positions. The Department of Agriculture has

since created two such positions in Hawaii.

CONCLUSION

The Federal Government is already carrying out many

activities under established policies and programs to

meet its responsibilities for stewardship of historic

re s o u rces. However, the challenges are tre m e n d o u s .

U n f o rt u n a t e l y, many Federal agencies have been stru ggling to meet their myriad responsibilities and to balance

conflicting priorities, and there has been a lack of firm

leadership and funding support to reverse this trend. 

While it is indeed encouraging to see that there are 

successful, established programs for taking care of the

N a t i o n ’s publicly owned historic re s o u rces and carry i n g

out related activities, it is also daunting to see how far

the Government must go to fully implement public stewa rdship policies and make the commitments necessary to

achieve those goals.
C H A P T E R 4

H I S T O R I C R E S O U R C E C A R E A N D M A N A G E M E N T —

S U M M A R Y O F F I N D I N G S

While many of the historic re s o u rces under Federal care

a re well-protected, and are being managed and used for

a variety of important public purposes, many are not for

a variety of reasons. If we could be assured that Federal

agencies were following carefully developed plans to

maximize and leverage the funding and staff re s o u rc e s

they have, engaging in proactive work to identify, protect, and pre s e rve the genuinely important places and

s t ru c t u res that define and pre s e rve our national charact e r, and consulting with the interested public about these

choices in a meaningful way, we might be able to re s t

e a s i e r. But we have no such assurance, and the evidence

to the contrary is alarming. 

Many of the historic and cultural resources under

Federal care—even some of the better known resources

administered by the National Park Service—are being

neglected or are in danger of being lost entirely through

lack of funds and insufficient attention. In some cases,

these resources are threatened with thoughtless development, insensitive uses, and poor management judgment. Neglect, deferred maintenance, and resulting

deterioration are also taking their toll.

Based on the Council’s review of Federal stewardship

of historic resources, it found:

Finding 1: There is a rich legacy of American 

history and culture in Federal care. 

The Federal Government owns, controls, manages,

or administers a substantial and significant array of

historic and cultural re s o u rces that collectively make

up a major portion of the Nation’s heritage. These

re s o u rces include some of the most important historic pro p e rties in the Nation and are inextricably

woven into the fabric of community life and experience throughout the country. They include not only

historic sites and monuments in the National Park

System, but also great public arc h i t e c t u re, public

works, and the evolution of America’s technological

p rowess, and vivid reminders of our military history,

our rich prehistoric past, and the diverse cultural

traditions that have contributed to modern

American society. 

Finding 2: Federal historic resources are 

valuable public assets. 

The Federal Government has a vested interest in its 

historic resources. In addition to their historic value,

these resources include major public buildings, engineering works, military installations, and other capital

improvements that embody a wide range of public values. The public value of these resources is enhanced by

their unique historic qualities. More o v e r, federally

owned historic resources should be recognized and

treated as both national and local assets, not only for

the part they play in the infrastructure of the Nation,

but also for their role in the local community.

These public values—and the long-term investments

associated with them—demand that Federal managers

do their utmost to care for heritage assets. In this way,

they fulfill their stewardship responsibility to the

American public. 

Finding 3: Many successes have been achieved and

much progress has been made by Federal agencies

in caring for and preserving these resources over

the last 30 years, but chronic problems exist.

As recently as the 1970s, there were few formal policies

or programs for protecting and managing historic

resources in Federal hands, aside from the units of the

National Park System. Since then, there has been considerable progress in Federal attention to the preservation and use of these resources. Today, most Federal

agencies with stewardship responsibilities have historic

p re s e rvation programs—at least on paper. Major

departments and independent agencies have designated

Federal Preservation Officers, as NHPA requires. Many

have made significant progress in inventory, planning

studies, and onsite preservation, interpretation, and

adaptive use of historic buildings, sites, and structures. 

The National Park Service has the clearest mission to

p rotect and interpret historic re s o u rces, but some other

agencies, such as the Bureau of Land Management and

the Forest Service, have made creative use of volunteer

p rograms, limited re c reation funding, and heritage

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tourism opportunities to support their steward s h i p

e ff o rts. The military services have made good use of special program funding to experiment with collaborative

and re s o u rce-based planning and maintenance initiatives. 

Overall, though, most Federal agencies lack a unified

strategy or implementation plan for identifying, evaluating, protecting, and managing the historic re s o u rc e s

e n t rusted to their care. Historic pre s e rvation policies,

p ro c e d u res, and techniques vary greatly from agency to

a g e n c y. Few comprehensive programs are in place that

fully integrate pre s e rvation into agency missions and

activities. Pre s e rvation activities are largely decentralized

and left to individual managers, and often conflict with

other priorities. Significant dedicated funding is virt u a l l y

nonexistent, and money for pre s e rvation activities often

must come from a variety of unrelated sources. Funding

and other attention are not necessarily keyed to priority

need or to importance of the re s o u rces, but to other 

factors that may be impossible to predict. 

Finding 4: Funding and staffing as currently 

structured are inadequate to meet the needs.

Asset management problems related to funding short f a l l s

a re growing daily. Maintenance is often deferred, and the

backlog of deferred maintenance needs is increasing. In

spite of this, cultural heritage program funding is not cons i d e red to be a high budget priority. For example, for the

B u reau of Land Management and the Forest Service, the

two public land-managing agencies with combined

responsibility for more than 460 million acres of land and

significant public re c reation and interpretive pro g r a m s ,

heritage funding amounts to less than 1 percent of their

respective budgets. This translates into unmet needs and

backlogs in inventory, evaluation, protection, and monitoring. In areas subject to significant population pre s s u re s

and public re c reation needs, similar difficulties are 

a ffecting interpretation, visitor access, and safety. 

N a t i o n a l l y, of more than two million civilian Federal

employees, only about one-tenth of 1 percent are trained

cultural re s o u rce professionals who have these pro g r a m

responsibilities as their primary duty. Perhaps another

one-tenth of 1 percent of employees are occupied with

a rchival and museum pre s e rvation. More commonly,

facilities management staff and environment pro t e c t i o n

specialists are assigned related historic re s o u rce management, planning, or review responsibilities as an “extra”

d u t y. Often these individuals have little expertise or training for this work, and its relationship to their principal

duties is poorly defined.

Finding 5: In addition to funding, adequate 

institutional and organizational support for historic

resources is often lacking in Federal agencies.

Some agency managers try to avoid controversial 

decisions, or practice risk management in deciding not

to comply with legal requirements. “corporate culture”

and the agency perception that historic preservation is

not part of the overall mission of the agency continue

to be major obstacles to better stewardship by some

Federal agencies. Many Federal employees are working

diligently and creatively to understand and care for the

historic resources entrusted to them. Too often their

efforts have not been adequately recognized or supported by supervisors and agency policy. Too much

good work is not institutionalized but dependent on

individual staff commitment and initiative. This is

laudable but neither sustainable nor transferable.

Both procedural and technical training are needed for

line and management employees, along with educational efforts that raise consciousness and awareness

among executives and decision makers at all levels

within the responsible agencies. Historic resource professionals who have responsibilities for carrying out the

agency’s historic resource stewardship mandates need

to be empowered to participate more fully in resource

management decisions and to provide meaningful input

to budget formulation and policy discussions. 

Finding 6: Public policymakers and managers 

need to be reminded that the Nation’s rich 

legacy is important and their actions can affect 

its stewardship.

Federal agencies need to demonstrate leadership in 

s t e w a rdship of historic re s o u rces by positive action and
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example. Leadership from both the executive and legislative branches is critical to agency recognition and appre c iation of the importance of maintaining this legacy for

f u t u re generations. While many of the heritage assets under

Federal care are well protected and managed and used for

a variety of important public purposes, many more are not.

With a few notable exceptions, individual Federal agencies

have not met their responsibilities, and there is a lack of

leadership and committed funding to reverse this trend. 

Many of the historic and cultural re s o u rces under Federal

c a re—even some of the better known pro p e rties administ e red by the National Park Serv i c e — a re being neglected

or are in danger of being lost entirely through lack of

funds, ignorance, and inattention. In some cases, they are

t h reatened with thoughtless development, insensitive

uses, and poor management judgment. A cultivated and

developed commitment to stewardship, flowing down

f rom agency leadership, as well as going up from an

a g e n c y ’s field staff (where the consequences of daily operations are understood and most management decisions

a re made), is the essential antidote. 

Finding 7: Lingering problems exist in 

the identification and evaluation of Federal 

holdings by their managers, which often lead 

to management difficulties.

By and large, Federal agencies do not have adequate 

i n f o rmation about the full scope, number, distribution,

and condition of the historic and cultural re s o u rces they

a re supposed to manage. Federal holdings total more than

650 million acres of land and some three billion square feet

of building space; less than 15 percent has been inventoried for historic re s o u rces. Without adequate baseline

i n f o rmation, sound management is impossible. As a re s u l t ,

Federal agencies are having difficulty keeping track of their

historic re s o u rce inventory, assessing, and understanding

the condition of their assets, and taking corrective actions.

Federal agencies have a tendency to “warehouse,”

rather than actively manage, many of the resources

under their care without consideration for their historic

value. In practice, this means that many agencies maintain a list of resources that might be historic, but have

never been fully evaluated for their significance. These

sites and structures are kept in a suspended status that

in effect keeps them in storage for some future evaluation and management treatment that may never come.

In practice, many of these resources may be neglected,

abandoned, and permitted to deteriorate without an

explicit decision or plan for their disposition that is

subject to public scrutiny and debate.

T h e re is a clear need for Federal personnel to better collect

and manage data about their re s o u rce holdings, and to be

m o re explicit about the decisions they make that have

management consequences. Federal agency managers,

too, must better understand the significance and important characteristics of their historic re s o u rces and use this

i n f o rmation to manage them more eff e c t i v e l y. For example, Federal stewardship would benefit from an objective

evaluation of the way in which Federal re s o u rce specialists

and managers make judgments about the significance and

relative value of historic re s o u rces. The evaluation should

include a comparative study of the relative importance of

historic re s o u rces throughout an agency’s holdings, as well

as cooperative projects that examine similar re s o u rce types

a c ross agency boundaries. Such studies should support

management plans and audits to help establish re s o u rc e

p rotection funding priorities.

Finding 8: Historic resource management is 

inadequately integrated with other needs.

Only a small portion of the Federal Govern m e n t ’s historic

re s o u rces are managed primarily to pre s e rve and interpre t

their historic values. The vast majority must serve the

c o n t e m p o r a ry needs of Federal agency missions and programs. Federal agencies need to increase the use of historic re s o u rces to meet their respective agency missions,

while maintaining those re s o u rces’ essential integrity.

Most Federal agencies do not have comprehensive plans

to identify and pre s e rve the best of these re s o u rc e s — t h e

places and stru c t u res that define the national character—

or have established mechanisms to use key historic

re s o u rces to meet their various missions.

All historic resources require consideration in planning,

but they do not necessarily warrant uniform treatment
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or management. Unfortunately, budget and staffing

problems have led to huge backlogs in evaluations of

historic resources to determine their significance and

value for agency uses. Such problems are also some of

the reasons for the enormous backlog in deferred maintenance, which is emerging as one of the most serious

impediments to successful resource management. A further result is that Federal agencies warehouse, rather

than actively manage, many of the resources under

their care without consideration for their historic value. 

Federal management of historic resources needs to be

better supported, more proactive, and directly tied to

comprehensive planning. Agencies need to operate

more holistically. This is especially true when long-term

facilities plans are being prepared, land-use decisions

are being made that may affect historic resources, or

multi-year budget needs are being identified. Federal

agencies are missing important opportunities to set and

operate under priorities that have been developed in

consultation with other interested parties and potential

public and private partners. 

Finding 9: Barriers to preservation often outweigh factors that would support and encourage

preservation efforts.

Few incentives exist that encourage Federal agencies to

do a better job and devise more creative solutions to

stewardship of historic resources. At the same time,

there are impediments to preservation in some agencies’ authorizing legislation, in the appro p r i a t i o n s

process, and in related policies that favor demolition,

new construction, and replacement rather than repair,

rehabilitation, and preventive maintenance of older

structures and facilities. 

For example, many existing facilities held and used by

these agencies are of historic significance—some of

them are of national importance—yet the process of

cost-benefit analysis, employing rigid and outdated

funding formulas, rental and lease-re t u rn margins, floor

a rea ratios, and similar planning and accounting

re q u i rements takes no account of intangible values or

the superior quality of historic stru c t u res, and often tips

the scales against rehabilitation and continued use.

D i rectives to reduce building inventories and simplify

p ro p e rty management through demolition, inactivation,

abandonment, and disposal may be in direct conflict

with historic re s o u rce pre s e rvation objectives. 

Federal agency missions also need to be viewed more

b roadly by managers as they relate to public trust and

s t e w a rdship needs, if these and similar obstacles are to be

o v e rcome. Perf o rmance incentives should be identified

that will help Federal managers incorporate historic

p re s e rvation into their work when it is called for. Historic

and cultural values need to be addressed more fairly and

openly in stewardship decisions, so they can be fully

weighed in facilities development and land use decisions. 

Finding 10: Existing laws are generally adequate,

but their implementation and the accountability

under them could be improved substantially.

The legal framework for Federal stewardship of historic

re s o u rces is comprehensive, and there are numero u s

statutes addressing Government-wide responsibilities, as

well as targeted agency re s o u rce management. Periodic

oversight occurs through the appropriations process or

c o n g ressional program reauthorization, supplemented

by General Accounting Office studies. Most of these

mandates, however, are self-policing. There is little

accountability and few incentives through established

p e rf o rmance standards, regular program monitoring, or

re p o rting for meeting the re q u i re m e n t s .

C u rre n t l y, few Federal strategic plans and annual

reports developed to comply with the Government

Performance and Results Act specifically acknowledge

historic resources, much less offer direction to their

employees on their responsibilities for these holdings.

Most do not set specific performance goals or measures

that relate to legal stewardship mandates. Those that

do, provide scant mention of stewardship requirements

focused on heritage. 

Until re c e n t l y, accountability re p o rts re q u i red under the

Chief Financial Officers Act and other related financial

management laws also paid little attention to this issue.
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H o w e v e r, in 1996 guidance was developed by the

Federal Accounting Standards Advisory Board (FA S A B )

for agencies to begin re p o rting on their heritage assets.

This assets re p o rting, including listing of significant natural and cultural re s o u rces under agency administration, was intended to ensure that agencies assemble

i n f o rmation on such assets, reveal and consider the

management costs and liabilities associated with them,

and characterize deferred maintenance needs. 

Early reports intended to comply with these standards

have been seriously deficient and poorly documented

by the agencies’ own standards as well as those of the

FASAB. Considerable more work is needed to develop

accurate baseline information in the future.

Finding 11: Federal agencies need to improve their

understanding of the views of public and private

parties who have particular interests in historic

resource preservation and use.

Federal agencies need to expand—and focus—eff o rts to

consult with concerned parties when deciding what

re s o u rces are important, to whom they matter, and how

they should be managed. This is particularly true when

it comes to re p resentatives of the communities in which

re s o u rces are located. Public disclosure and consultation

is re q u i red by law when agencies are considering various undertakings, but many agency managers view

these re q u i rements as time-consuming hindrances rather

than opportunities for creative problem solving. While

Federal agencies must consult with a wide range of

stakeholders when they make major land use or pro p e rty management decisions, a number of agencies could

make major improvements in the way in which they

identify stakeholders and seek their views in planning

and decision making. 

Understanding re q u i res effective communication.

Agencies need to develop mechanisms to better inform

and engage communities and business groups, such as

those involved with heritage tourism, in decisions

about resource protection and access. They also need to

develop better means for addressing the concerns and

interests of groups who have a special affinity with particular historic resources, such as Indian tribes and

other Native Americans. 

Finding 12: More emphasis on effective 

collaboration and partnership could help

achieve common goals.

Federal agencies need to enter into more public-private

p a rtnerships to leverage re s o u rces for promotion, 

p rotection, and enhancement of historic values.

“ P a rtnership” has become a popular term, but Federal

agencies are not adequately exploiting the potential for

p a rtnerships with the private sector to pre s e rve and

use historic re s o u rces, often because of legal or administrative impediments. Some laws and policies that are

intended to restrict questionable lobbying activities or

potential conflicts of interest for Federal employees

have the unintended effect of limiting the nature and

extent of partnerships with the private sector. 

M o re o v e r, the most successful current partnerships and

related agency program initiatives are neither well known

nor widely emulated throughout the Federal

G o v e rnment. This is due in part to lack of staff and funding for proactive program planning, but may also be

attributed to poor information sharing and pooling of

re s o u rces among Federal agencies or Federal, State, and

local government organizations with similar missions. 
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MAJOR FEDERAL STEWARDSHIP RESPONSIBILITIES: 

DID YOU KNOW...?

■ Four Federal departments (Agriculture, Defense, Energy, and Interior) manage more than 665 million acres

of public land, nearly 30 percent of the United States.

■ Federal agencies own nearly three billion square feet of building space nationwide in more than 425,000

buildings, with the Defense Department owning the most, followed by GSA-administered Federal buildings,

Postal Service facilities, veterans centers, and other holdings.

■ Federal agencies own or control land and buildings in 1,419 historic districts out of approximately 10,000

districts that are listed in the National Register of Historic Places.

■ Aside from historic districts, Federal agencies nationwide own or control 3,185 historic properties 

containing 7,804 individual contributing buildings, sites, structures, and objects, out of approximately

61,000 non-district listings in the National Register of Historic Places.

■ Federal agencies are entrusted with more than 200 buildings, sites, structures, and objects that have been

designated by the Secretary of the Interior as National Historic Landmarks, out of 2,231 listings.

■ Federal agencies have inventoried about 750,000 archeological sites on public lands, but more than 

85 percent of Federal and tribal lands remain unsurveyed.

■ Each year, nearly 100,000 Federal and federally assisted construction projects and other actions are

reviewed nationally for their possible impact on important historic resources as part of the planning and

decision process.

■ The National Park Service and the Smithsonian Institution together hold more than 175 million historic and

cultural objects and scientific specimens, and other Federal agencies also have large and diverse artifact and

museum collections.

■ The National Archives and Records Administration’s 33 public records facilities hold about 21.5 million

cubic feet of original textual materials—more than four billion documents, maps, charts, and architectural

drawings—as well as nearly 14 million still pictures and posters, more than nine million aerial photographs,

300,000 reels of motion picture film, 200,000 sound and video recordings, and 7,600 computer data sets.

Other Federal agencies also have significant historic archival holdings.

■ Federal preservation programs and activities account for less than 1 percent of Federal budgets, and fulltime professional historic resource personnel make up just over 0.1 percent—about 2,000 professionals—

of the total Federal workforce of approximately two million employees.

F I G U R E 7

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C H A P T E R 5

S U C C E S S F U L S T E W A R D S H I P O F T H E P A S T —

N E E D S A N D R E C O M M E N D A T I O N S F O R I M P R O V E M E N T

A large part of the Nation’s heritage is in Federal hands,

but the Government does not always meets its basic public

s t e w a rdship responsibilities to that heritage. Section 110 of

N H PA directs Federal agencies to “assume re s p o n s i b i l i t y

for the pre s e rvation of historic pro p e rties which are owned

or controlled by such agency,” and to establish and carry

out pre s e rvation programs to meet the purposes of the law. 

During its two-year study, the Council drew a number

of conclusions from our observations on Federal stewardship and how well Federal agencies meet their

responsibilities. We have identified a number of general needs, and have concluded that change is warranted

in several specific areas that are essential to better

Federal stewardship. These areas fall under three broad

themes: Leadership, Commitment, and Accountability.

The Council also believes there are certain key ingre d i e n t s

to achieving success in this complex endeavor, and there

a re some good current programs and practices that could

s e rve as useful agency and government-wide models.

Enhanced collaboration and partnership, among Federal

agencies as well as between Federal and non-Federal parties, is one important implementation strategy that needs

special attention.

LEADERSHIP: BUILDING A HISTORIC

RESOURCE STEWARDSHIP ETHIC

A p p ropriate leadership is critical. Leadership in historic

re s o u rce stewardship has many facets. An atmosphere that

can support a national and Government-wide pre s e rv a t i o n

ethic must be established, and basic principles and policy

d i rection laid down. If stewardship of historic re s o u rces is

to be successful and realize its true potential, it is important that everyone in the Federal Government who is in a

planning, decision making, or implementation position

understands the importance of the issues, and that stewa rdship has been determined to be a national priority that

has an accompanying commitment from the top. 

A vision for the value of the Nation’s heritage needs to be

s h a red with both Federal employees and the American

people, and the potential benefits associated with the 

p rotection and enhancement of this heritage made clear to

all. The case must be presented publicly, capitalizing on

s t a rtling images and symbols to drive home the message

that this is important. Not only must policies be art i c u l a ted, but some assurance must be given that the means to

c a rry out the policies must be actively sought and secure d .

But other requirements also come into play. Leadership

involves offering successful examples and ideas, offering encouragement, and finding and providing material support. It also involves incentives for potentially

competing interests to work together in creative ways,

and to promote solutions to common pro b l e m s

through partnerships among diverse parties. 

Leadership Needs

Leadership Need 1: Emphasize the importance of

heritage as a national priority.

Since the passage of the National Historic Pre s e rvation Act

in 1966, it has been the official policy of the Federal

G o v e rnment to exercise leadership in historic pre s e rv a t i o n .

To meet that mandate, framed by Congress and appro v e d

by the President, it is imperative first, that the branches of

G o v e rnment explicitly recognize, support, and encourage

p re s e rvation as a national priority, and second, that each

agency of the executive branch have the internal capability

to conduct its actions in a manner that promotes the protection and enhancement of historic values while it also

avoids unnecessary harm to historic re s o u rc e s .

The First Lady, the White House Millennium Council,

the National Trust for Historic Pre s e rvation, and the

National Park Service have demonstrated leadership

with the creation and promotion of “Save America’s

Tre a s u res” (see Appendix 3). Aw a rds programs, such as

the Department of Defense cultural re s o u rce awards, the

Design Aw a rds administered by the General Serv i c e s

Administration and the National Endowment for the

A rts, and the Department of Tr a n s p o rtation enviro nmental awards, offer positive incentives to employees

and others. When the National Park Service and the

S e c re t a ry of the Interior decided to go forw a rd with the

National Park Serv i c e ’s well-publicized demolition of the

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G e t t y s b u rg National Battlefield Tower during summer

2000, it captured media and public attention.

The National Trust for Historic Pre s e rvation also dramatizes the importance of heritage successfully with its

“Eleven Most Endangered List,” announced each year.

U n f o rt u n a t e l y, the Federal Government has no mechanism similar to the Trust list. A clear and firm message is

needed from the highest levels of Government that promotes the protection and enhancement of the Nation’s

historic re s o u rces as a national priority.

Leadership Need 2: Make it clear that stewardship is

a part of every agency’s mission.

Many agencies acknowledge the difficulties of integrating

historic pre s e rvation into their missions if they are not

explicitly directed to do so in authorizing or enabling legislation. They also acknowledge that it is difficult to overcome the existing corporate culture and attitudes about the

relative importance of historic and cultural steward s h i p .

Some agencies have detailed internal guidance, even

beyond obvious procedural compliance matters involving

Section 106 of NHPA or other legal mandates. However,

much of the existing direction contains deficiencies longrecognized by agency specialists and others. Some of it is

outdated, incomplete, or misdirected in relation to current concerns and problems. Much of it is impractical as

guidance for direct field re s o u rce management use. Some

of the technical guidance is not widely available or accessible, and for practical (often budgetary) reasons, it has

not been disseminated through the most efficient and

e ffective means, such as through electronic media. 

Existing internal pro c e d u res may be inconsistent with

c u rrent agency organization, planning and decisionmaking steps, policies, programs, or budgeting. Diff e re n t

agencies with similar missions and re s o u rce holdings

may still have widely differing policies, standards, and

guidance on common re s o u rce concerns or issues. The

bulk of many agencies’ internal operating manuals and

policy guidance may have been developed as much as 15

or 20 years ago, and in many cases pre-date the 1992

amendments to NHPA .

The few agencies that have relatively large staffs of historic

p re s e rvation professionals and a large and diverse port f o l i o

of historic re s o u rce assets often bear an internal agency

“ c u l t u re” problem that may hamper agency eff o rts to successfully integrate Section 110 historic re s o u rce management needs into other activities of the agency. Ingrained

attitudes about mission priorities or agency operating practices may be difficult to modify. Unless this problem is

a d d ressed, through better educational programs and more

e ffective perf o rmance measures developed by the agencies

i n t e rn a l l y, eff o rts to integrate historic pre s e rvation activities

into the policies, pro c e d u res, and operations of many agencies will be superficial and ineffectual over the long ru n .

Leadership Need 3: Promote a vision for successful

stewardship and lead by example. 

A number of agencies have been developing vision 

statements and goals for their heritage stewardship programs in recent years. In 1999 and 2000 the General

S e rvices Administration, the National Park Service, and

the Forest Service have each gone through this process and

developed priorities for policy and budgetary implementation. Other agencies, such as the Department of Energ y,

have begun similar eff o rts. The Department of Defense, in

having to respond to such a vision developed extern a l l y

rather than internally (for example, through legislation

establishing the Legacy Resource Management Pro g r a m ) ,

has embraced and begun to internalize much of this vision.

Such visions are important first steps to implementation.

H o w e v e r, in order to have some effect on agency behavior

and practice, they re q u i re detailed follow-through and nurturing, and must be supported and sustained over the long

t e rm. Adequate funding and staffing support are critical. It

remains to be seen whether many of these agency visions

can be successfully internalized and gain staying power and

usefulness beyond their initial pro m o t i o n .

Leadership Need 4: Facilitate historic resource stewardship through both direct and indirect means. 

Federal agencies have both direct and indirect tools at

their disposal for accomplishing good stewardship. On

the one hand, they need to actively solicit and take
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advantage of opportunities to cooperate with 

non-Federal parties as well as other Federal agencies

who may have complementary pre s e rvation goals. On

the other hand, they need to appreciate their power to

persuade and encourage others by positive example and

by the leveraging of financial and other re s o u rces. 

W h e re federally owned historic re s o u rces contribute 

significantly to the fabric, character, and social and economic viability of local communities, or where poor stewa rdship would have serious consequences for localities or

regions, the demonstration of Federal leadership in

p re s e rvation becomes even more critical. Many import a n t

historic re s o u rces under Federal ownership or control are

i m p o rtant local landmarks or offer unique opport u n i t i e s

to become centerpieces for community re v i t a l i z a t i o n

plans. Debates about the fate of closed or downsized 

m i l i t a ry installations, unneeded post offices, energy facilities, and other potentially valuable historic assets must

consider all of their special values and the educational,

inspirational, and economic opportunities they re p resent. 

Leadership Need 5: Engage and educate the public

about heritage values. 

The responsibility to be stewards of our collective 

heritage can, and should, include educating the public

about the historic resources on the public lands or in

Federal property holdings. 

The National Park Service is in the fore f ront of these

e ff o rts, because of its particular mission to “pre s e rv e

u n i m p a i red the natural and cultural re s o u rces and values

of the National Park System for the enjoyment, education, and inspiration of this and future generations.”4 6

NPS uses many programs and approaches to carry out

this charge. However, the responsibility and opport u n i t i e s

for meeting these needs do not stop with NPS. 

For example, “Intrigue of the Past” is a program that was

developed and supported by the Bureau of Land

Management that attempts to engage the public, in particular young people, about their cultural heritage through 

p a rt i c i p a t o ry archeology and other related activities. The

p rogram has been suffering from a lack of funding support ,

but could play a valuable role in enhancing public education

about our heritage. BLM has also developed a publication

highlighting many of its most significant areas for public visitation and re c reation use, in part to help celebrate and re cognize its 50th anniversary in 1996.4 7 The U.S. Fish and

Wildlife Service is contemplating similar public outre a c h

and other projects for its centennial observance in 2003. 

At many historic Federal buildings and courthouses, the

General Services Administration’s “First Impre s s i o n s ”

initiative is highlighting and promoting some of its premier public buildings through public bro c h u res and other

materials that point out key historic features of courthouse and Federal building public spaces. There is gre a t

public interest and potential support for public tours and

onsite interpretation of historic re s o u rces at military

installations, within national laboratories, and at other

Federal holdings throughout the country. Educational

p rograms directed at K-12 education enhancement, or in

conjunction with scouting and other youth org a n i z a t i o n s ,

p resent numerous opportunities to Federal agencies if

developed and carried out with appropriate public and

private sector institutions, organizations, and businesses. 

Recommendations

The Federal Government must emphasize its role in 

p rotecting and pre s e rving the Nation’s heritage, and seek

and advocate historic re s o u rce stewardship in part n e r s h i p

with non-Federal parties. Periodic reminders from the

P resident, the Cabinet, and agency leadership, as well as

f rom Congress, would help to re i n f o rce and emphasize the

i m p o rtance of historic re s o u rce stewardship thro u g h o u t

the Federal establishment. A significant component of such

a message could be a directive to executive branch agencies

to take the lead in caring for the re s o u rces under their stewa rdship and demonstrating the value of these re s o u rces as

i m p o rtant assets for a variety of public benefits. 

Leadership Recommendation 1: The President

should clarify the executive branch’s leadership role

in promoting historic values and preserving historic

46 NPS Cultural Resources Strategic Plan, National Leadership Council, National Park Service, 1997.

47 Beyond the National Parks: A Recreation Guide to Public Lands in the West, Smithsonian Institution Press, Washington, DC, 1998.
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resources, and direct the highest levels of the

Federal Government to make a sustained commitment to history and historic preservation. 

The President should direct his Cabinet and other

executive branch agencies to carry out their stewardship responsibilities in a more effective and consistent

m a n n e r. Such a directive would ensure better implementation of existing mandates and impro v e d

accountability by:

■ Clarifying and emphasizing the Federal

G o v e rn m e n t ’s leadership role in promoting 

historic values and the pre s e rvation of 

historic resources.

■ P roviding a sound basis for planning, budget 

f o rmulation, and decision making by dire c t i n g

Federal agency heads to establish the state of the

N a t i o n ’s historic re s o u rces by assembling baseline

i n f o rmation and ongoing assessments of the number

and condition of important historic re s o u rces under

Federal ownership and contro l .

■ Ensuring better management accountability

t h rough integration of historic pre s e rv a t i o n

p rogram responsibilities into agency re g u l ations, management policies, and operating 

p ro c e d u res, and designation of a senior agency

o fficial with oversight responsibility for historic

p re s e rvation activities.

■ P romoting interg o v e rnmental cooperation and

p a rtnerships, especially with State and local

g o v e rnments, Indian tribes, and Native

Hawaiian organizations as well as the private

s e c t o r, and fostering private initiative and

investment in the pre s e rvation and use of 

historic re s o u rc e s .

■ Mandating policies and guidance that give 

p re f e rence to historic re s o u rces in management

decisions, including allowances for a public intere s t

“intangible values” component in cost-benefit

analyses and other fiduciary decisions.

■ P roviding a means for private contributions to be

used for the pre s e rvation and enhancement of

Federally owned or controlled historic re s o u rc e s .

■ D i recting the development of a focused training

p rogram responsive to basic Federal steward s h i p

needs and the responsibilities of Federal managers

and policy makers.

Leadership Recommendation 2: Congress should

commission an independent policy study on the

public costs and benefits of preserving historic

resources that could be used to help set future 

legislative priorities.

Such a study would offer an objective analysis that

could be used as a basis for legislative changes in such

areas as public resource management, tax policy, public infrastructure modernization, and Federal appropriations. The National Research Council or a similar,

publicly chartered institution should be so charged.

Leadership Recommendation 3: Congress should

provide funding for the National Trust for Historic

Preservation to pursue partnerships with Federal

agencies in order to enhance stewardship of his -

toric resources, especially through public outreach. 

The National Trust should provide assistance with 

p romotional publications, public educational activities, an

e l e c t ronic clearinghouse for potential private partners, and

similar eff o rts in keeping with its congressional chart e r. 

Leadership Recommendation 4: The National

Park Service, the Council, and Federal agencies

should cooperatively develop and maintain more

effective training for agency personnel at all

organizational and program levels. These programs should include government-wide historic

preservation awareness training for policy-level

officials keyed to stewardship performance.

NPS should seek sufficient funding and other continuing

s u p p o rt for its Federal Pre s e rvation Institute initiative,

established at the National Center for Pre s e rv a t i o n
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Technology and Training in September 2000. A 

cooperative endeavor among NPS, the Council, several

major cabinet departments, Nort h w e s t e rn State

University of Louisiana, and other organizations, academic institutions, and governments, the institute can

f o rm the nucleus for senior executive training, interagency educational cooperation, and information sharing. 

COMMITMENT: TAKING CARE OF THE

NATION’S HISTORIC PUBLIC ASSETS

In association with leadership actions, a clear commitment

needs to be made to follow through in caring for the

N a t i o n ’s historic public assets. Individual Federal agencies

and their leaders and other key decision makers must

understand and appreciate the value and management

potential of the historic re s o u rces for which they are

responsible. Sufficient financial and personnel re s o u rc e s

must be found and sustained to carry out the job. Agencies

must ensure that appropriate re s o u rce management 

priorities are set that are consistent with national policy

objectives and leadership direction. Management practices

must be developed and carried out that integrate 

p re s e rvation goals with specific mission needs.

Commitment means thinking strategically, knowing the

inventory of historic resources as well as its significance

and value to meet public needs, and being able to set

responsible priorities for dealing with those holdings.

Planning and resource management activities must be

integrated and responsive to the varied and extensive

needs of modern land and property management, and

ways must be found to maintain, manage, and use

assets wisely while making informed decisions about

them. Ability to make such decisions, with an appropriate level of input from affected and interested stakeholders and other affected or interested part i e s ,

assumes an adequate level of information and analysis.

Mission objectives and other needs must be balanced

effectively and responsibly.

It is clear, however, that as we enter the 21st century, we

have not truly accepted, or even acknowledged, the

responsibility entrusted to us. We have not given the men

and women chosen to be the caretakers, promoters, and

advocates of the Govern m e n t ’s historic re s o u rces the right

tools or sufficient re s o u rces to do the job we ostensibly

a re asking them to do. We have also not done our best to

retain talented individuals, and ensure that their talents

and knowledge are passed on to others and succeeding

generations of public serv a n t s .

Commitment Needs

Commitment Need 1: Provide adequate funding

and personnel. 

All agencies are desperately short of funding and staff

to meet their basic obligations. To do anything beyond

the absolute minimum is even more problematic.

In many agencies, the lack of dedicated budgets for

p re s e rvation activities is endemic. Agency historic

re s o u rce management personnel must make do with limited support from operations and maintenance accounts,

facility management accounts, or environmental pro t e ction and remediation funding. Often, such personnel are

f o rced to compete for funds with costly enviro n m e n t a l

cleanup activities, such as decontamination, asbestos

removal, and lead paint abatement. They also compete

against maintenance activities that include grass cutting,

snowplowing, and road re s u rf a c i n g .

As outlined in a recent re p o rt on stewardship of

Federal facilities:

Inadequate funding for maintenance and repair programs in the federal government is a long-standing

p roblem. Plans and programs for maintenance have

received little support from executive or legislative

decision makers for several reasons. First, there is a

tacit assumption that maintenance can always be put

o ff for a month, a year, or even five years in favor of

c u rrent operations and more visible projects with

seemingly higher payoffs. Second, managers of federal

agencies have generally failed to convince the public or

political decision makers that funds invested in preventive and timely maintenance will be cost eff e c t i v e ,

will protect the quality and functionality of facilities,
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and will protect the taxpayers’ investment. Thus, 

decision makers, who tend to have short - t e rm outlooks, have not often been swayed to support actions

with results that are realized over the long term .4 8

Ve ry limited funds are available for land use planning,

including identification and evaluation of historic re s o u rc e s

on agency-controlled lands. Often these activities must re l y

on construction projects or redevelopment schemes, and

a re assigned a small percentage of this money.

Most agencies and historic re s o u rce staff try to meet

their funding, staffing, and other program needs

t h rough a variety of mechanisms, including begging

and borrowing from other agency programs, or by

entering into cooperative agreements where possible

and collaborating with other programs, Federal

agencies, or non-Federal part i e s .

Since NHPA was amended in 1992, some agencies have

done a better job than others in creatively using and

focusing the financial and other re s o u rces at their disposal, and a few (notably the Department of Defense) have

had congressional support for “fenced” conservation and

p re s e rvation funding.4 9 So what is the solution to this and

other aspects of the situation? 

One approach would be to dedicate funding and make

it available on a matching, competitive basis for award

to Federal agencies with significant resources that have

demonstrated serious threats, like the current Save

America’s Treasures fund. Save America’s Treasures has

provided critical dollars that are targeted or “fenced”

for preservation work. It is also an excellent example of

a public-private partnership. To date, $60 million in

Federal funds has been made available, which has

helped to leverage $37 million in private funds.

Historic resources owned or controlled by a wide range

of Federal agencies have benefitted.

A second approach would be to increase funding

overall for agency historic re s o u rce stewardship and

related activities, based in part on agency holdings,

responsibilities, and internal and external threats to

re s o u rces. Beginning in FY 1991, a very successful

p rogram in the Department of Defense known as

Legacy was established under the Department of

Defense Appropriations Act. Legacy is another major

p rogram involving “fenced” funds, and has enjoyed,

and continues to enjoy, bipartisan support and the

s u p p o rt of both the Bush and Clinton administrations. Begun at an appropriation level of $10 million

(including both natural and cultural re s o u rces), the

p rogram reached a high of $50 million in the thre e

consecutive years of FY 93-95. It is currently funded

at $15 million, of which just over $14 million had

been released by early September 2000, and $12 million was requested for FY 2001 (appropriations pending). In the past four fiscal years alone, DoD has

received $45 million, with probably about 40 perc e n t

of that amount being spent on historic re s o u rce 

c o n c e rns and 60 percent on natural re s o u rc e s .

A third approach would be to use a combination of 

dedicated funding, re a p p o rtionment of existing agency

budgets, and other revenue-generating techniques such as

private user fees or commercial concessions contracts.

P e rhaps the most far- reaching and ambitious targ e t e d

funding at the present time is the Recreational Fee

Demonstration Program, which was authorized by

C o n g ress in 1996 by the Omnibus Consolidated

Rescissions Act (later amended and extended). The program has now been authorized through FY 2001 by the

FY 1999 Interior appropriations bill. Four agencies—the

National Park Service, the U.S. Fish and Wildlife Serv i c e ,

the Bureau of Land Management, and the U.S. Fore s t

S e rv i c e — w e re authorized to retain 100 percent of funds

collected at selected sites in the form of entrance and user

fees, with 80 percent of those funds to be retained onsite

and used for improving visitor facilities, pro t e c t i n g

re s o u rces, and administering the program. Results to date

have been extremely successful. Surveys of public visitors

and the local land managers have found that both are

s u p p o rtive of this approach, as long as the fees are used

for onsite needs rather than being collected and re t u rn e d

to the General Tre a s u ry. 

48 Stewardship of Federal Facilities: A Proactive Strategy for Managing the Nation’s Public Assets, National Research Council, 1998, p. vi.

49 This includes, for example, DoD’s Legacy Resource Management Program, passed in 1991 as part of the Defense Authorization Act.
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R e s o u rces like prominent National Park lodges have 

benefitted from concession contracts that have re q u i re d

c reation of Capital Improvement and Cyclic Maintenance

accounts. In some cases, 20 percent of gross revenues have

been dedicated to such investments, 10 percent each for

capital improvement and re g u l a r, continuing maintenance. 

Other possibilities to improve funding in general for

Federal stewardship include revolving funds, tru s t

accounts, and public bonds.5 0

Commitment Need 2: Ensure adequate expertise,

training, and retention of a professional work force. 

Training and incentives to retain an experienced and 

p rofessional work force need to be developed. The re t e ntion problem for experienced pre s e rvation personnel is

acute, and widespread downsizing, hiring freezes, and the

l u re of the private sector are contributing to this. In GSA,

for example, asset managers are attracted to the private

sector for both economic and other reasons. Experienced

individuals who understand the complexities of Federal

policy and operations (including public sector funding

constraints) are enticed to leave, and training is needed on

a continual basis that can never quite keep up with the

Federal workforce turn o v e r.

In the Department of Defense, the Civil Engineers Corps

O fficers (CECOS) naval school offers courses in compliance with historic pre s e rvation laws that are open to staff

of all the services and the U.S. Coast Guard. These courses

have been off e red consistently over the past several years

and have been integrated into the CECOS curr i c u l u m .

M o re re c e n t l y, the National Park Service has announced

the establishment of the Federal Pre s e rvation Institute at

the National Center for Pre s e rvation Technology and

Training in Natchitoches, Louisiana. The intention is to

i n c rease training opportunities for Federal agency personnel responsible for stewardship of historic re s o u rces. In

cooperation with other Federal agencies and the pre s e rv ation community, the institute will coordinate education

and training for policy makers as well as other Federal

employees whose decisions affect the pre s e rvation of the

N a t i o n ’s heritage assets. 

The goals of the institute are “to be a national leader in

p re s e rvation training, to provide all Federal employees

with the skills needed to carry out the National Historic

P re s e rvation Act and related laws, and to instill a stewardship ethic throughout the Federal workforce.” The institute

is organizing its activities into four principal areas: a stewa rdship awareness program aimed at senior Federal executives; a pre s e rvation training clearinghouse on the Intern e t ;

a program of special subject, targeted training seminars on

a variety of technical, legal, and policy-related topics; and

establishment of training and certification standards. 

The institute is working closely with Nort h w e s t e rn State

University of Louisiana, the Advisory Council on Historic

P re s e rvation, and re p resentatives from Federal agencies.

Funding and other organizational support is needed 

to fully realize and continue this eff o rt. Other pro g r a m s ,

and a new look at more effective ways to develop and

retain experienced and credentialed staff to meet Federal

s t e w a rdship responsibilities, need to be explored in depth.

Commitment Need 3: Establish adequate knowledge

of the historic resources that agencies manage. 

Responsible stewardship and associated decisions must

rely on available information on re s o u rces held by agencies: their significance, condition, management status, and

potential for agency or other use. Unfortunately agencies

50 The Department of the Interior and Related Agencies Appropriations Act for 2001 (P.L. 106-291) recently increased funding for stewardship and related programs in several of the Interior bureaus and the Forest Service, although much of this funding is committed to general land

management activities, payments to local governments in lieu of taxes, or infrastructure improvement and repair on resources that are not heritage assets. Earlier efforts to boost funding support through passage of the Conservation and Reinvestment Act were not successful. However,

money is provided to continue the Save America’s Treasures initiative, and to increase funds for BLM land use planning, NPS condition assessments, historic trails, and battlefield protection, and other support directly related to historic resource stewardship. Title VIII of the law creates

a six-year Land Conservation, Preservation, and Infrastructure Improvement program within the budget; “this action recognizes land conservation and related activities as critical National priorities and provides a mechanism to guarantee significantly increased funding for critical

land acquisition and other land protection programs. [However], the program is not mandatory and does not guarantee annual appropriations”

(Joint Explanatory Statement of the Committee Conference, H.R. 4578, House Rep. 106-914, September 29, 2000). 
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a re often working with incomplete, outdated, or otherw i s e

inadequate data about their resource holdings. 

The National Park Service has estimated that with a conc e rted eff o rt it may be able to catch up with simple cataloguing of its museum collections in another 20 years.5 1

P a rt of the problem seems to be time and money; part of

the problem is one of perception. When asked about the

number and condition of its heritage assets and deferre d

maintenance needs for historic re s o u rces, the U.S. Fish and

Wildlife Service responded that it might be able to answer

that question if given 10 years to do so.5 2 The National

A e ronautics and Space Administration noted that its heritage assets amounted to 20 buildings and stru c t u res, 103

“air and space displays and artifacts,” and six miscellaneous items, but apparently overlooked not only other prehistoric and historic re s o u rces on its lands, but also the

active and historic launch facilities that it operates at the

Kennedy Space Center in Florida that are listed in the

National Register of Historic Places as a historic district.5 3

The Federal Preservation Officer for the Department of

Veterans Affairs has recently completed revisions to the

agency’s database of historic resources. This and similar examples should be promoted, and information

about the cost and time to develop such information

should be made available to other Federal agencies. In

decentralized agencies, mechanisms for summarizing

existing information for headquarters and other use—

similar to the historic resources publication produced

by the Department of the Navy on its holdings—could

be pursued cost-effectively in a variety of ways.

Both short - t e rm and long-term means should be pursued

for supporting and improving upon this track re c o rd and

o ffering incentives to improve databases and evaluations.

Commitment Need 4: Set appropriate stewardship

priorities within Federal agencies. 

Many pro p e rty managers, such as the General Serv i c e s

Administration, are encouraged by Congress, their Chief

Financial Officers, and the Office of Management and

Budget to adopt a businesslike approach to managing

the pro p e rties under their jurisdiction and control. This

is difficult to dispute as a general policy. However, business portfolio management needs to be able to re c o g n i z e

the broader public interest and intangible public values

being served and supported by Government agencies.

The characterization of historic re s o u rces as “assets”

should not lose sight of the fact that monetary value

must be balanced with community value and meaning to

the national patrimony. 

For example, the U.S. Postal Service may not think that a

p a rticular building fits in with its “asset portfolio” priorities, but this view may be at odds with community views

of what is a local landmark and should be pre s e rved. To o

often business practices have off e red insufficient pro v isions for these intangible values, which cannot be laid out

on a spread sheet or figured simply into market re t u rn .

Such values need to be included in the equation. 

Commitment Need 5: Integrate historic resource

management with other activities and mission

requirements. 

Most Federal agencies lack a unified strategy or 

implementation plan for identifying, evaluating, protecting, and managing the historic resources entrusted

to their care. Preservation activities are largely decentralized and left to individual land, property, and program managers; this approach has both strengths and

weaknesses. However, significant funding is in short

supply, and money for preservation activities often

must come from a variety of sources only indirectly

related to historic resource stewardship. 

The Sierra Nevada National Forest Framework for

A rcheological Resource Management is a good example

of an agency establishing a way to determine re l a t i v e

i m p o rtance of historic re s o u rces (principally arc h e o l o g y )

and establish priorities for pre s e rvation, conservation, or

release from special management constraints. On a

51 Accountability Report, National Park Service, FY 1997.

52 Annual Report, U.S. Fish and Wildlife Service, 1997.

53 Accountability Report, National Aeronautics and Space Administration, 1998.
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b ro a d e r, agency-wide basis, the Army is promoting the

development of Integrated Cultural Resourc e

Management Plans for each of its installations that are

intended to take an account of maintenance and re p a i r

needs, demolition, training activity impacts, and other

c o n c e rns, and establish standard operating pro c e d u res as

well as funding and decision priorities.

T h e re is an intrinsic value of Federal pro p e rties, and the

Federal Government presence in the local community—

i.e., the post office, courthouse, lease, forest, national park

u n i t — re p resents the “face” of the Federal government in

that locale. The General Services Administration’s Design

Excellence Program is a good example of this sort of creative thinking. Its essence is the assumption that if a local

community is going to have only one Federal building or

c o u rthouse, that pro p e rty should be a source of community pride and support rather than an object for derision

as in some previous Federal building projects. 

The theme of Federal agencies acting as “good 

neighbors” must be taken seriously by executives and

managers. Agencies need to actively work with the communities in which they are housed. One of the most frequent complaints the Council hears about Federal agencies is that they are housed “over there” and do not

interact with the local community. In Butte, Montana,

for example, the rather significant Federal presence had

no re p resentation on the local Chamber of Commerc e .

The Federal Government had little interaction with the

community until it had nearly decided to move to other

q u a rters. The proposed move galvanized the community,

and relations impro v e d .

Given the increased importance of security issues, part i cularly since the Oklahoma City Federal building bombing

several years ago, the Federal presence can seem like an

a rmed camp that is hostile to the local community. When

a local Federal agency cannot get funding to fix the ro o f

and the building is deteriorating, community activists and

local government officials may not be aware of the situation. More effective communication, and active cooperation between Federal managers and local governments as

well as other interested organizations, could be of gre a t

assistance in garnering public support for steward s h i p .

Recommendations

The Federal Government must provide consistent, 

reliable, and adequate funding to meet its stewardship

responsibilities. It should also provide dedicated funds

for historic re s o u rce stewardship, while re m o v i n g

obstacles to cost-effective care and use of resources.

Commitment Recommendation 1: The Administration and Congress should work together 

to improve Federal funding levels, based on 

performance and needs in accordance with the

Government Performance and Results Act. 

■ Special multi-year funding for specific agencies that

is earmarked for historic pre s e rvation activities (similar to the Department of Defense Legacy Resourc e

Management Program) should be considere d .

■ The Administration and Congress should work

together to expand and permanently authorize a

R e c reation and Conservation Fee program, based

on the current Recreation Fee Demonstration program authorized by Section 315 of the Omnibus

Consolidated Rescissions Act of 1996 and amended under P.L. 104-134. Currently authorized fee

collection agencies (National Park Service, Fish

and Wildlife Service, Forest Service, and the

B u reau of Land Management) should be expanded to include the U.S. Army Corps of Engineers

and the Bureau of Reclamation.

■ The Administration and Congress should work

together to continue to fund the Save America’s

Treasures grants program at a responsible level.

■ The Administration and Congress should 

consider adding a provision to the Historic

P re s e rvation Fund or a similar authority that

sets aside a small amount of funding for grants

of less than $50,000 on a 75/25 matching basis

to be used for project or program seed money,

re s o u rce condition assessments, feasibility studies, and emergency re s o u rce stabilization and

p rotection. Such funds are basic to successful

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d i fficult to segregate for these uses within 

existing agency budget priorities. 

■ The National Park Service should develop and

maintain an information base that is accessible to

other Federal agencies and the public on National

Park System concessions and concessioner agre ements. NPS should share its experience in working

with concessioners to establish capital impro v ement and cyclic maintenance account set-asides, as

well as other mechanisms for re h a b i l i t a t i o n ,

restoration, and maintenance of historic re s o u rces. 

Commitment Recommendation 2: Congress should

amend Section 111 of NHPA to permit Federal

agencies to continue to use historic properties 

or portions of historic properties that are leased 

or exchanged with non-Federal parties, through

lease-back arrangements or other mechanisms. 

■ Agencies should be authorized to carry over 

p roceeds from leasing under Section 111 if 

necessary in order to expend them on related

preservation p rojects and activities.

■ Congress should enact an amendment to the

D e p a rtment of Defense’s leasing authorities

under 10 USC 2667 that is similar to the amendment recommended for Section 111 of NHPA.

Both the House and Senate versions of the FY

2001 Defense Authorization Act (H.R. 4205)

have variants on language that would authorize

DoD to lease properties that are not excess to its

needs. This legislation should be passed, with the

language amended to explicitly include mention

of historic resources.

Commitment Recommendation 3: Federal agencies

should identify and remove accounting barriers 

and other administrative impediments within their 

control to the use and leasing of historic resources in

accordance with Sections 110(a)(1) and 111 of NHPA. 

Federal agencies should work with the National Park

Service, the General Services Administration, and the

Council, in consultation with the Office of

Management and Budget, to overcome apparent policy

impediments to effective outleasing and other use of

historic re s o u rces where the National Historic

Preservation Act authorities appear to conflict with

other management practice. 

ACCOUNTABILITY: MAKING

PRESERVATION DECISIONS IN 

THE PUBLIC INTEREST

Federal agencies need to be accountable for their 

decisions related to stewardship of historic resources,

and be able to demonstrate that those decisions are in

the public interest. At the same time, accountability can

be used as a tool—an “action forcing device”—to

ensure that the process of management and the act of

decision making includes adequate information, sufficient public involvement, and appreciation and understanding of the consequences of agency actions. 

Agencies with re s o u rce management responsibilities are

regularly exhorted to operate in a businesslike manner

and be publicly accountable. That should mean more

than justifying stewardship activities and results in pro f i t -

loss terms, although such justification is obviously important. It should also mean that the agency’s activities are

w e l l - i n f o rmed, responsible, appropriate, and generally

c o s t - e ffective. Unlike commercial enterprises, the Federal

G o v e rnment sets other policies and goals to advance the

public interest, and these public interest considerations

need to explicitly provide for an adequate accounting of

how the Nation’s heritage is being protected and

enhanced for present and future generations.

Accountability Needs

Accountability Need 1: Set appropriate goals, 

monitor performance, measure success, and open

decisions to public scrutiny.

As articulated in a recent report on stewardship of

Federal facilities (not just historic ones) by the National

Research Council: 
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The ownership of real pro p e rty entails an investment

in the present and a commitment to the future .

Ownership of facilities by the federal government, or

any other entity, re p resents an obligation that

re q u i res not only money to carry out that ownership

re s p o n s i b l y, but also the vision, resolve, experience,

and expertise to ensure that re s o u rces are allocated

e ffectively to sustain that investment. Recognition

and acceptance of this obligation is the essence of

s t e w a rdship. Yet, despite the millions of stakeholders

and expenditure of hundreds of billions of taxpayer

dollars in federal facilities, we have not been good

s t e w a rds of our public buildings. The continuing

deterioration of federal facilities is apparent to the

most casual observer and has been documented by

n u m e rous studies. Still, little has been done to check

the decline, and few people in government are willing

to accept responsibility for it.5 4

The Government Perf o rmance and Results Act re q u i re s

not only agency strategic plans for periods of six years

( c u rrently through 2003), but also annual perf o rm a n c e

plans that link budgets to achievement of strategic goals.

Periodic audits and re p o rts from Chief Financial

O fficers, as re q u i red by the Chief Financial Officers Act,

and agency Inspectors General may also be of assistance

in monitoring pro g ress or needed adjustments.

U n f o rt u n a t e l y, specific direction on carrying out national

p re s e rvation policies and orders in these accounting and

re p o rting tools is often non-binding or completely lacking,

and the protection and enhancement of historic re s o u rc e s

remains at a distinct disadvantage in relation to other

national priorities or agency missions. Many pro v i s i o n s

have never been fully implemented, and are not likely to

be anytime soon. Despite the Government Perf o rm a n c e

and Results Act and other management and financial

accounting re f o rms, there remains a lack of accountabilit y. Few Federal agency mission statements, strategic plans,

p e rf o rmance standards, and accounting systems specifically acknowledge or offer direction to their employees on

their responsibilities for historic re s o u rces. Most do not set

specific perf o rmance goals or measures that relate to 

s t e w a rdship mandates, and they should. 

Accountability Need 2: Ensure financial 

accountability and legal compliance.

Some agencies, such as the military services of the

D e p a rtment of Defense, conduct periodic Enviro n m e n t a l

Compliance Audits to identify problems and establish

priorities for corrective action. Each DoD service has an

e n v i ronmental audit system: The Army has the

E n v i ronmental Compliance Assessment System; the Air

F o rce, the Environmental Compliance Assessment

Management Program; the Navy, the Enviro n m e n t a l

Quality Assessment. These systems provide for both

i n t e rnal auditing by installation personnel and extern a l

auditing by superior commands. Although originally

designed to track RCRA and CERCLA compliance, all

the systems now also look at cultural re s o u rce management. The systems are designed to flag and lead to the

c o rrection of deficiencies.

Under the Chief Financial Officers Act, Federal agencies

w e re to begin re p o rting their “heritage assets” and

d e f e rred maintenance needs beginning with the FY 1998

re p o rting period. The Federal Accounting Standard s

A d v i s o ry board, established in 1990 by the Secre t a ry of

the Tre a s u ry, the Director of the Office of Management

and Budget, and the Comptroller General, issues various

Federal Financial Accounting Standards for use by agencies in their financial re p o rting. Standard 8, which deals

with Supplementary Stewardship Reporting, was published and disseminated in July 1996. Amendments were

issued or proposed in 1999 to offer additional guidance

on stewardship re p o rting and on accounting standard s

for heritage assets with multiple Government uses.

Accountability Need 3: Balance potential conflicts

over resource protection and use, with due consideration for the views of community leaders,

stakeholders, and the public.

T h e re are impediments to pre s e rvation in some agencies’

authorizing legislation, appropriations, and policies that

favor demolition, new construction, and re p l a c e m e n t

rather than re p a i r, rehabilitation, and preventive maintenance of older stru c t u res and facilities. Many existing

54 Stewardship of Federal Facilities, National Research Council, National Academy Press, 1998.
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facilities held and used by these agencies are of historic

significance, some of national importance, yet funding

allocation formulae are often not sympathetic to historic

rehabilitation opportunities or needs.

Recommendations

The Federal Government must improve its accountability for historic re s o u rce stewardship and fully 

integrate historic re s o u rce management concerns with

other priorities.

Accountability Recommendation 1: The President

should direct Federal agencies to document 

and report regularly on the condition of important

historic resources under their control as a 

basis for responsible planning, budgeting, and 

decision making. 

■ The President should direct agencies to report

annually to the Council and the National Park

Service with a listing of their 10 most-endangered historic resources, for inclusion in the

Council’s annual report, beginning at the end of

FY 2001. 

■ Congress should provide funding to NPS for the

quadrennial review of significant threats to properties included in or eligible for inclusion in the

National Register of Historic Places, as called for

in NHPA, Section 101(a)(8). 

Accountability Recommendation 2: The President

should direct Federal agencies to enhance the

organizational placement and role of the Federal

Preservation Officer (established under Section

110(c) of NHPA) to ensure that each agency has an

effective focal point for preservation activities.

The Federal Pre s e rvation Officer should be the

a g e n c y ’s principal program officer for pre s e rv a t i o n

activities, and this program responsibility should complement any senior official who may be designated 

to provide policy and budget oversight responsibility 

in accordance with other Presidential direction 

(see Recommendation 1, above). 

Accountability Recommendation 3: The Administration, with support from Congress, should

ensure that Federal agencies fully integrate historic

preservation responsibilities and needs into strategic plans, performance standards, performance

measures, and management and accounting 

systems, consistent with the Government

Performance and Results Act, the Chief Financial

Officers Act, the Performance Management and

Recognition System, and related mandates.

■ The Director of the Office of Management and

Budget should amend its guidance on the

Government Performance and Results Act to

ensure that strategic plans, desired outcomes,

and annual performance plans of Federal agencies that own or manage public property include

measures and reporting on resource stewardship

such as the management of historic resources

under agency jurisdiction or control. 

■ The Director of the Office of Management and

Budget should request the Financial Accounting

S t a n d a rds Advisory Board (FASAB) to establish a

Task Force on Cultural Resources, and to charge the

task force, in consultation with the Council, with

reviewing and, if appropriate, revising or clarifying

the FASAB guidance on heritage assets contained in

the Statement of Federal Financial Accounting

S t a n d a rds 8, “Supplementary Steward s h i p

R e p o rting,” in order to improve consistent and

comparable data collection and re p o rting on historic re s o u rces under Federal ownership or control. 

Accountability Recommendation 4: Federal agencies

should establish and maintain internal audit programs to monitor compliance with historic preservation laws and regulations and recommend corrective

action for critical resource protection needs.

Federal agencies, through the Office of Management

and Budget or the Chief Financial Officers, should be

encouraged to share information on environmental

compliance auditing systems that might assist them in

directing funding to critical resource protection needs.
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Accountability Recommendation 5: Federal agencies

should improve the effectiveness and consistency of

how they seek and consider the views of outside 

parties, including the general public, in their 

stewardship decisions.

Federal agencies, with the assistance of the Office of

Management and Budget, should share information on

effective public involvement in planning, decision making, and ongoing resource management. This should

include Federal experience with citizen advisory councils and support foundations, coordination with tribal,

State, and local governments, and consultation with

private stakeholders, as well as the laws governing public disclosure and involvement in Federal decisions.

Potential best practices for public involvement and

stakeholder consultation should be disseminated

among agencies through electronic clearinghouses,

training programs, and other means.

Accountability Recommendation 6: Federal agencies

should develop awards programs and performance

incentives to support historic preservation.

Federal agencies should be encouraged to establish

national awards for historic re s o u rce steward s h i p ,

similar to those that have been established by the mili t a ry services, and to submit agency award winners to

the Council for consideration of “Lasting Impact”

a w a rds every three years (see Council Commitments,

page 76).

COLLABORATION: FINDING AND

WORKING WITH PARTNERS

Many Federal agencies have realized for a long time

that they cannot meet their stewardship responsibilities

alone. Collaboration is a way agencies can successfully

meet the needs and recommendations outlined above.

Beyond finding additional funding or people power,

such partnerships offer many other benefits.

For several years, the regional offices of the National Tru s t

for Historic Pre s e rvation worked with military installations and pre s e rvation organizations to encourage them to

work together on a variety of joint projects. The success of

that venture is illustrated by a publication pre p a red by the

National Trust and funded by the Department of Defense

Legacy Resource Management Program and the National

Park Service, entitled Working Together: Achieving

Cultural Resource Management Goals through

P a rt n e r s h i p s .5 5 This publication provides excellent examples and advice on partnership and collaboration that all

Federal agencies, not just DoD, can use.

It highlighted four benefits for Federal agencies from 

initiating and fostering partnerships. In part i c u l a r, pre s e rvation organizations working together can lead to “sharing of the workload, a proactive approach to compliance,

i m p roved public relations, and an enhancement of

m o r a l e . ”5 6 We would add two additional benefits to this

list: the ability to gain not only expertise but focused interest and enthusiasm that might otherwise be lacking for a

p a rticular project, and encouragement for Federal agencies

to “buy-in” to the idea of being stakeholders actively participating in management outcomes that they care about.

Collaboration Needs

Collaboration Need 1: Stretch scarce resources

through partnerships. 

The General Accounting Office (GAO) pre p a red a study

of Federal building and facility partnerships in 1999. 

It noted that “our work and that of others over the last

several years has identified several important weaknesses in Federal agencies’ management and maintenance of

facilities and real pro p e rt y,” and went on to list some of

these weaknesses. They included strategic thinking and

capital planning; dealing with deferred maintenance;

inability to address underutilized and unneeded pro p e rties; and lack of adequate or consistent data on condition

of facilities, maintenance and repair costs, and operating

versus capital improvement budgetary needs.

55 Working Together: Achieving Cultural Resource Management Goals through Partnerships, National Trust for Historic Preservation,

Legacy Project, 1997.

56 Ibid, p. 3.
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GAO observed that “federally owned buildings and land

need to be strategically acquired, managed, and disposed

of so that the taxpayer’s re t u rn on the investment is maximized.” One possible solution is for Federal agencies to

enter into partnerships with the private sector thro u g h

contracts or agreements. “These arrangements typically

involve a government agency contracting with a private

p a rtner to renovate, construct, operate, maintain, and/or

manage a government agency contracting with a private

p a rtner to renovate, construct, operate, maintain, and/or

manage a facility or system, in part or in whole, that 

p rovides a public serv i c e . ”5 7

GAO found that five key factors were present in the

successful partnership projects that it examined: 1)

there had been some key catalyst for change; 2)

Congress had enacted legislation to provide a statutory

basis for partnership and allow the agency to keep the

revenues from the partnership; 3) new organizational

structures and expertise were provided for to facilitate

agency interaction with private partners; 4) business

plans or some similar mechanism were created to help

guide informed decision making by the agency and the

partnership; and 5) the partnership had key support

from the local community and other project stakeholders.58 While GAO believed that all of these factors were

important, they singled out Congress’ role and appropriate legal authority to act creatively as perhaps the

single-most critical factor.

Collaboration Need 2: Promote incentives and 

minimize disincentives affecting partnerships. 

The Department of Defense offers an example of how

tweaking existing authorities could facilitate agencies

obtaining private funds. DoD is currently authorized to

accept private gifts if in connection with the maintenance and operation of a school, hospital, library,

museum, etc. (10 USC 2601). Such authority could be

expanded to include receipt of gifts for preservation of

specific historic resources.

Collaboration Need 3: Learn from successful and

innovative partnerships. 

The recent renovation of the Washington Monument 

is certainly a pre m i e re example of pooling of public and

private sector funds. Another high-profile example is the

work of the Statue of Liberty-Ellis Island Foundation,

Inc. (in cooperation with the National Park Serv i c e ) ,

established to raise funds for the restoration of the Statue

of Liberty ($87 million) and key buildings on Ellis Island,

notably the Main Building ($162 million).

The National Park Foundation is a nonprofit partner of

the National Park Service that was chart e red by

C o n g ress, and offers one model for public-private partnership support. Another somewhat diff e rent example is

p rovided by the Maine Lights program, through which

Coast Guard lighthouses have been both successfully

leased and also conveyed out of Federal ownership.5 9

A number of Federal agencies have worked with 

p a rtners, contractors, concessioners, or on their own

to develop successful Facilities Tours of their active

facilities. Some of these public tours and re l a t e d

events are off e red daily; others are more limited for

s e c u r i t y, safety, privacy, or other reasons, and are

a rranged around special open-house days a few times

each year. NASA has had a great deal of success with

this, and works with commercial as well as non-pro fit organizations to accommodate the 2.75 million

annual visitors to the Kennedy Space Center in 

addition to its other centers. 

Collaboration Need 4: Promote interagency 

cooperation and pooling of resources and knowledge. 

There is a strong need for more collaboration and

resource pooling between Federal entities, although

there are often practical and organizational barriers to

be overcome. Faced with the difficulty of managing and

caring for aging space hardware and other artifacts of

57 Public-Private Partnerships, General Accounting Office, February 1999, p. 1.

58 Ibid, p. 3.

59 The new National Historic Lighthouse Preservation Act (P.L. 106-355) is intended to facilitate the transfer of these unique and desirable

resources for preservation, recreation, and public interpretation purposes.
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the manned space program, NASA entered into a 

cooperative agreement with the Smithsonian Institution

to offer the National Air and Space Museum long-term

loans for display, as well as right of first refusal for

items or high-tech components that were no longer

needed by NASA for active space programs. 

The Forest Service and the Bureau of Land Management

often work together on their adjoining lands in the western

United States, and all land management agencies have re a lized in the last few years that there are increasingly compelling reasons to do so. On a modest scale, at Lake Ta h o e ,

the Forest Service and Bureau of Land Management were

engaged in a land exchange that resulted in Forest Serv i c e

acquisition of a historic mansion and its land, the Whittier

Estate. Under the terms of the exchange, the house is 

being rehabilitated and will be managed by a nonpro f i t

o rganization as a conference center. 

M o re bro a d l y, under the National Fire Plan and 

wildland fire emergency appropriations established in

the FY 2001 budget, this type of cooperation and common approach for BLM and the Forest Service is actually mandated by law, and all of the land management

agencies participating in the National Fire Center or

subject to catastrophic wildland fires will have to share

common agenda and resources. 

Collaboration Need 5: Capitalize on public support

from active volunteers.

T h e re are many excellent examples of voluntary

e ff o rts that do or could offer support for historic

re s o u rce stewardship needs. In the National Parks,

m o re than 70,000 persons volunteer their time and talents annually to work as a Volunteer in the Parks in

National Park Units across the country. Each park unit

has a coordinator who matches needed skills with volunteers. The volunteers serve in many capacities, many

of which relate to the protection, enhancement, management, and interpretation of historic re s o u rc e s .

Among other things, volunteers work at inform a t i o n

desks; present living history demonstrations; write or

design visitor bro c h u res; and give guided walks or

evening campfire programs. 

P a s s p o rt in Time (PIT), begun in 1989, is a volunteer

p rogram of the Forest Service. PIT provides opport u n ities for the public to work with professional arc h e o l ogists and historians on National Forests and grasslands

a c ross the country. Projects include diverse activities such

as archeological excavation, surv e y, oral history, or historic stru c t u re restoration. There is no registration fee. A

semi-annual newsletter announces current and upcoming volunteer opportunities, age and skill re q u i re m e n t s ,

if any, and minimum time commitment expected. The

goal of PIT is to pre s e rve the Nation’s past with the help

of the public. A related, informal network called Friends

of Pit includes private individuals dedicated to supporting PIT and all heritage management eff o rts within the

USDA Forest Service. Through letters and personal visits, Friends of Pit makes sure that Forest Service off i c i a l s

know how important the opportunity is to the public to

contribute to heritage re s o u rce management.

These and other models need to be explored, and lessons

l e a rned from their successes and failures made available

m o re broadly for Federal agencies to apply and adapt to

their own situations and needs.

Recommendations

Collaboration Recommendation 1: The Administration and Congress should work together to

establish appropriate mechanisms for Federal

agencies and the private sector to promote successful public-private partnerships. This should

include removing legal impediments to the establishment and financial support of non-profit educational groups and volunteer associations who

can assist with Federal stewardship work. 

Congress should request that the General Accounting

Office prepare an analysis of legal impediments that

may exist to the establishment and financial support of

nonprofit educational groups and volunteer associations who might otherwise assist with Federal stewardship of historic resources. Congress should use the

results of this analysis to craft legislation that facilitates

such support to land and property management agencies, including fund-raising activities. 
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Collaboration Recommendation 2: The Administration should encourage Federal agencies to 

outlease or expedite conveyance of surplus 

historic resources that could be better managed,

preserved, and used by other Government entities

or the private sector.

C o n g ress should consider currently proposed (and possibly

additional) changes to the Federal Pro p e rty and

Administrative Services Act that would facilitate transfer of

historic re s o u rces for pre s e rvation and public use purposes. 

COUNCIL COMMITMENTS

The Council will work with Federal agencies, other

appropriate public and private partners, and the

President’s Council on the Arts and Humanities to

develop and present a consistent and powerful

message linking American history, cultural values,

and Federal stewardship. This message will 

promote historic preservation as a valid and

important national priority.

The Council will explore the development of a series of

video productions focusing on the Federal

Government’s historic resource stewardship role, in

cooperation with the President’s Council on the Arts

and Humanities, the National Trust for Historic

Preservation, and a cable outlet such as The History

Channel or The Learning Channel. Several individual

films could examine different agencies, their resources,

and the challenges they face in caring for historic properties and develop human interest in the employees and

citizen volunteers engaged in such work. 

The Council will work with the Administration and

selected Federal agencies to promote appropriate

policies and implementing guidance on property

management, new facilities construction, and

rehabilitation of existing facilities to give preference or equal weight to historic resource management decisions, and include allowances for a

public interest component in cost-benefit analyses and other decisions involving the public trust. 

The Council will examine opportunities for new joint

guidance with agencies as well as the creative use of

various existing programmatic tools at its disposal that

are contained in its regulations implementing Section

106 of NHPA, “Protection of Historic Properties” (36

CFR Part 800). 

The Council will also work with Federal agencies 

to develop administrative and other incentives for

proactive Federal management planning that is

responsive to historic resource management needs,

promotes public-private partnerships, and increases

effective public involvement in stewardship planning. 

The Council will propose for funding support the

“Lasting Impact” Aw a rds for Federal Historic

P re s e rvation. The awards would be presented to

Federal agencies for projects and programs that have

had or are likely to have a lasting impact on historic

resource stewardship and the promotion of a public

preservation ethic in the U.S., and that best exemplify

Federal leadership and commitment in the spirit of the

National Historic Preservation Act. If funded, awards

would be given for both Stewardship and Partnership

initiatives every three years, beginning in FY 2002.

AFTERWORD

The Federal Government has a rich and varied array of

historic resources under its care. They portray the

major themes of American history, celebrating the

achievements of the Nation and serving as important

icons to communities across the land. Managing these

unique public assets presents many challenges, but the

Federal Government has the capability, if effectively

mobilized, to ensure the sound stewardship of these

irreplaceable resources for future generations. 

The Council’s recommendations provide a blueprint for

meeting these challenges. We look forw a rd to working

with the executive and legislative branches of

G o v e rnment, as well as many other public and private

p a rties, to further the goal of effective Federal steward s h i p

of our national patrimony. 
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C H A L L E N G E S O F F E D E R A L S T E W A R D S H I P

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Advisory Council on Historic Preservation. 1994. Defense Department Compliance with the National Historic

Preservation Act: Section 202(a)(6) Evaluation Report. Prepared in partnership with the Department of

Defense, Legacy Resource Management Program. Washington, DC: Author.

Advisory Council on Historic Preservation. 1991. Balancing Historic Preservation Needs with the Operation of

Highly Technical or Scientific Facilities. Report to the Committee on Interior and Insular Affairs,

Subcommittee on National Parks and Public Lands, and the Committee on Science, Space, and Technology,

U.S. House of Representatives. Washington, DC: Author.

Barnes, Christine. Great Lodges of the West. 1997. Bend, Oregon: W.W. West.

Buccino, Sharon, Charles Clusen, Ed Norton, and Joanna Wald. 1997. Reclaiming Our Heritage: What We Need

to Do to Preserve America’s National Parks. Washington, DC: Natural Resources Defense Council and

National Trust for Historic Preservation.

Bureau of Land Management. 2000. “Strategic Paper on Cultural Resources At Risk.” Unpublished manuscript.

Bureau of Land Management. 1999. Public Rewards from Public Lands. Washington, DC: Author.

Bureau of Land Management. 1999. Your Lands, Your Legacy—1998 Annual Report. Washington, DC: Office of

the Chief Financial Officer.

Bureau of Land Management. 1998. Beyond the National Parks—A Recreation Guide to Public Lands in the West

(Mary E. Tisdale and Bibi Booth, Eds.). Washington, DC: Smithsonian Institution Press.

B u rton, Lloyd, and David Ruppert. 1999. “Bear’s Lodge or Devil’s Tower: Intercultural Relations, Legal Pluralism,

and the Management of Sacred Sites on Public Lands.” C o rnell Journal of Law and Public Policy Vol. 8, No. 2.

Department of Defense. 2000. Defense Environmental Quality Program: FY 1999 Annual Report to Congress.

Washington, DC: Author.

Department of Defense. 2000. Environmental Security: Defending Our Future. Department of Defense

Environment, Safety, and Occupational Health Report. Washington, DC: Author.

Department of Defense. 1994. The Benefits of Cultural Resource Conservation—Commander’s Guide.

Washington, DC: Legacy Resource Management Program. 

Department of Energy. No date. “Stewards of a National Resource.” Washington, DC: Author.

Department of the Interior. 1999. “Cultural Resource Management, Bureau of Land Management.” Audit Report

No. 99-I-808. Washington, DC: Office of Inspector General.

Department of Transportation. 1999. DOT Consolidated Financial Statement FY 1998. Washington, DC: Office of

the Chief Financial Officer.

R E S E A R C H S O U R C E S A N D B I B L I O G R A P H Y
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R E S E A R C H S O U R C E S A N D B I B L I O G R A P H Y

Federal Accounting Standards Advisory Board. 1999. “Amendments to Accounting for Property, Plant, and

Equipment, Measurement and Reporting for Multi-Use Heritage Assets” (draft). Statement of Recommended

Accounting Standards No. 16.

Federal Accounting Standards Advisory Board. 1999. “Amendments to Deferred Maintenance Reporting.”

Statement of Federal Financial Accounting Standards No. 14 (April 1999). Washington, DC: Author.

Field, Donald R., et al. 1998. “National Park Service Managers’ Views Toward the Recreational Fee

Demonstration Program, 1997.” Pennsylvania State University, University of Wisconsin-Madison, and Utah

State University.

General Accounting Office. 2000. BLM and the Forest Service: Land Exchanges Need to Reflect Appropriate

Value and Serve the Public Interest (GAO/RCED-00-73). Washington, DC: Author.

General Accounting Office. 2000. Federal Buildings: Billions Are Needed for Repairs and Alterations.

(GAO/GGD-00-98). Washington, DC: Author.

General Accounting Office. 2000. Military Housing—Continued Concerns in Implementing the Privatization

Initiative (GAO/NSIAD-00- 71). Washington, DC: Author.

General Accounting Office. 1999. Public-Private Partnerships: Key Elements of Federal Building and Facility

Partnerships (GAO/GGD-99- 23). Washington, DC: Author.

General Accounting Office. 1998. Deferred Maintenance Reporting: Challenges to Implementation

(GAO/AIMD-98-42). Washington, DC: Author.

General Accounting Office. 1998. Implementation of Federal Historic Preservation Program Can Be Improved

(GAO/RCED-88-81). Washington, DC: Author.

General Accounting Office. 1991. Federal Buildings: Actions Needed to Prevent Further Deterioration and

Obsolescence (GAO/GGD-91- 57). Washington, DC: Author.

General Services Administration. 1999. Held in Public Trust: Public Buildings Service Strategy for Using Historic

Buildings. Washington, DC: GSA Public Buildings Service.

General Services Administration. 1996. “Federal Real Property Asset Management Principles.” GSA Bulletin

D-240. 61 FR 201: 53295-53929 (October 16, 1996). Washington, DC: Author.

General Services Administration. No date. Proceedings of the Roundtable and Public Forum: Determination of

Reuse for a National Historic Landmark Property, General Post Office. Washington, DC: Author.

Kelly, Marion, and Nancy Aleck. 1997. Makua Means Parents—A Brief Cultural History of Makua Valley.

American Friends Service Committee, Hawaii Area Program.
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Lewis, Andre w, Karen Waddell, T. Luke Young, and Elizabeth Johnston. 1998. Working Together—Achieving Cultural

R e s o u rce Management Goals through Partnerships. Washington, DC: National Trust for Historic Pre s e rv a t i o n .

National Aeronautics and Space Administration. 1999. 1998 Accountability Report. Washington, DC: Office of

the Chief Financial Officer.

National Endowment for the Humanities. 1999. My History Is America’s History—15 Things You Can Do to Save

America’s Stories. Washington, DC: Author.

National Park Service. 2000. “Cultural Resources Challenge” (September 2000 draft).

National Park Service. 2000. “Dam Good Archeology—The Bureau of Reclamation’s Cultural Resources

Program.” CRM Vol. 23, No. 1. 

National Park Service. 2000. Vanishing Treasures—Year End Report, Fiscal Year 1999. Washington, DC: Author.

National Park Service. 1999. America’s Historic Landmarks at Risk: Report to the 106th Congress.

Washington, DC: Author.

National Park Service. 1998. Management Policies to Guide the Management of the National Park System.

Washington, DC: Author.

National Park Service. 1998. National Park Service Accountability Report—Fiscal Year 1997.

Washington, DC: Author.

National Park Service. 1998. Secretary of the Interior’s Standards and Guidelines for Federal Agency Historic

Preservation Programs Pursuant to the National Historic Preservation Program. 63 FR 79: 20495-20508

(April 24, 1998). Washington, DC: Author.

National Park Service. 1997. “A Challenge for the Military Mission—Preservation in the Armed Forces.” 

CRM Vol. 20, No. 13. 

National Park Service. 1997. “Cultural Resource Management Guideline.” Release No. 5. 

Washington, DC: Author.

National Park Service. 1997. Cultural Resources Strategic Plan. Washington, DC: Author.

National Park Service. 1996. “1996 Survey of Federal Agencies’ Historic Preservation Programs.” Prepared for

Hon. James Hansen, Chairman, Committee on Resources, Subcommiteee on National Parks, Forests, and

Lands, U.S. House of Representatives. Washington, DC: Author.

National Research Council. 1998. Stewardship of Federal Facilities: A Proactive Strategy for Managing the

Nation’s Public Assets. Committee to Assess Techniques for Developing Maintenance and Repair Budgets for

Federal Facilities; Board on Infrastructure and the Constructed Environment; and Commission on Engineering

and Technical Systems. Washington, DC: National Academy Press. 
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Tennessee Valley Authority. 1997. “Generation to Generation—A Short History of TVA.” 

Washington, DC: Author.

Tennessee Valley Authority. 1997. “Tennessee Valley Authority Government Performance and Results Act Strategic

Plan, FY1997-2002.” Washington, DC: Author.

Tennessee Valley Authority. 1996. “Dams and Power Plants.” Washington, DC: Author.

U.S. Army. 1999. Historical and Archaeological Resources of the U.S. Army Garrison, Hawaii.

Washington, DC: Author.

U.S. Army. No date. “Army Environmental Programs.” Washington, DC: U.S. Army Environmental Center.

U.S. Conference of Mayors, Special Committee on Historic Preservation. 1966. With Heritage So Rich. 

New York: Random House.

U.S. Department of Agriculture. 1999. “Forest Service Timber Sale Environmental Analysis Requirements,

Washington, DC.” Evaluation Report No. 08801-10-At. Washington, DC: Office of Inspector General.

U.S. Fish and Wildlife Service. 1998. Shared Commitments to Conservation, 1997 Annual Report. 

Washington, DC: Chief Financial Officer.

U.S. Forest Service. 1999. Heritage—It’s About Time! A National Strategy. Washington, DC: Author.

U.S. Forest Service. 1999. “A Legacy of Hope: Managing America’s Natural Resources in the 21st Century.”

Washington, DC: Author.

U.S. Forest Service. 1998. “Heritage—It’s About Time.” Southwestern Region News (December 1998).

U.S. Navy. 1997. Historic and Archeological Resources Protection Planning Guidelines. Washington, DC: Author.
Appendix 1 

POLICY AND PROGRAM RECOMMENDATIONS 

PROVIDED TO SPECIFIC AGENCIES AS PART OF THIS STUDY

During the course of the Council’s two-year initiative to study Federal historic re s o u rce stewardship, Council members

and staff met with a number of Federal agencies and off e red specific advice and recommendations to improve their stewa rdship eff o rts. The recommendations made to these agencies are outlined below. Work with several of these agencies

is ongoing, and three agencies (GSA, Department of Energ y, and Army) have existing or nascent agreements with the

Council for mutual cooperation on program improvements and training initiatives. 

General Services Administration

GSA should carry out the recommendations and commitments contained in its 1999 re p o rt, Held in Public Trust: Public

Buildings Service Strategy for Using Historic Buildings, and should make the re p o rt available to a broad Federal audience.

GSA should work with the Council to:

■ Build on pro g ress it is making to “institutionalize” a pre s e rvation ethic within its regional offices through furt h e r

training and education, in cooperation with other part i e s .

■ Develop and implement model pro c e d u res for public involvement and consultation on site selection, lease 

acquisition, and use changes for GSA projects. Such pro c e d u res should be designed to be used as “best practices”

by other agencies for these same issues.

Develop model documents and standard conditions for transfers/disposal of historic re s o u rces, given the incre a s i n g

number of GSA excessing/disposal actions for its own pro p e rties as well as those of other agencies. These models should

be designed to streamline and coordinate the re g u l a t o ry process and increase the potential for public access and use. 

Department of Energy

G e n e r a l

■ DoE should develop a strategy and Standard Operating Procedures to ensure that its immediate short-term

needs do not preclude long-term preservation options. Such a strategy should ensure that preservation values

are fairly considered, along with budget constraints, security, contamination and environmental cleanup 

concerns, and changing mission requirements.

■ DoE should take steps to ensure protection, retention, inventory, and long-term preservation and interpretation of historic artifacts, records, drawings, and archival materials associated with its historic facilities.

■ DoE should consult with NASA, its contractors, and support groups on mechanisms for developing or improving 

visitor interpretation facilities and site tours at its major laboratories, including Oak Ridge, Los Alamos, and Hanford .

■ DoE should work with the Council to:

— Develop historic preservation training and education for staff to more effectively meet the requirements of

the National Historic Preservation Act.

— Streamline departmental procedures to ensure timely, comprehensive, and cost-effective compliance with

Federal preservation laws, particularly in situations where historic properties are in secured areas, or must

be decontaminated.

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— Develop guidance on alternative mitigation strategies for historic properties scheduled for demolition and

the significant equipment and artifacts contained in them that is scheduled for removal, and how to

increase use of museums and other public outreach mechanisms to accomplish preservation goals.

— Explore ways to make the application of environmental standards for the decontamination of contaminated properties sensitive to historic preservation concerns.

Specific to Manhattan Project (summary from “Recommendations and Preservation Options for Manhattan Project

Signature Facilities at Oak Ridge and Hanford Reservations,” February 2001)

■ DOE’s efforts to preserve and present the legacy of the Manhattan Project through identification of its

Signature Facilities is a laudable first step toward recognizing the significance of these facilities. The Expert

Panel commends the Secretary of Energy for creating the Corporate Board on Historic Preservation to ensure

consideration of historic preservation issues at the highest levels of DOE management.

■ The long-term value of the Signature Facilities lies in their historic significance, not as operating facilities. DOE

should not be expected to assume all financial costs for preserving this historic significance, and should foster

partnerships with other Federal agencies, the private sector, and State and local governments to ensure the

preservation of these historic sites.

■ DOE should pursue, in consultation with the National Park Service and other interested parties, National

Historic Landmark designation for the Signature Facilities. The ultimate goal should be the formal establishment of these historic properties as a collective unit administered for preservation, commemoration, and 

public interpretation in cooperation with the National Park Service. 

■ DOE should ensure that historic preservation concerns are addressed by its facility contractors early in the

planning and environmental review process to decontaminate and decommission its Signature Facilities and

other historic properties. Priceless artifacts and records associated with and located in Signature Facilities and

other historic structures must not be lost due to misguided or insensitive maintenance and cleanup operations.

■ Continued cooperation between DOE and interested State and local organizations must take place to ensure

that the Graphite Reactor at Oak Ridge and the 105-B Reactor at Hanford serve as museums to interpret the

story of the Manhattan Project. Working with the American Museum of Science and Energy at Oak Ridge and

the 105-B Reactor Museum Association and the Columbia River Exhibition of History, Science, and

Technology at Richland, DOE should consider making these two Signature Facilities the focal points of 

education and tours of these respective facilities.

■ DOE must ensure that the historic significance of its two remaining working Signature Facilities, the Y-12 

Beta-3 Racetrack at Oak Ridge and the 221-T Chemical Separations Plan at Hanford, is considered early and

comprehensively in their management and operation.

■ A comprehensive examination of alternatives to total demolition should be undertaken as DOE proceeds with

the decontamination and decommissioning of the K-25 Building at Oak Ridge. All feasible preservation

options need to be reviewed by all interested parties before determining a final course of action.

Department of Defense, Department of the Army

The Department of the Army should work with the Council to:

■ Continue to support an Office of Historic Pro p e rties under the Assistant Secre t a ry of the Army for Installations and

E n v i ronment, to better deal with the Arm y ’s conflicting responsibilities to protect historic re s o u rces while cost-eff e ctively operating and maintaining Army installations, and reducing unneeded and costly installation infrastru c t u re .

Appendix 1 Continued
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■ Pursue refinement of privatization initiatives, particularly those dealing with military housing, that address historic

p re s e rvation concern s .

■ Continue work on streamlining Army policies and procedures and integrating historic preservation activities

with installation land use and management planning needs.

■ Build on and support advisory groups similar to the Ukanipo Heiau Advisory Group in Hawaii and the Friends

of Fort Sam Houston in Texas as examples of workable and exemplary community partnerships. 

■ Continue to support means for raising Army personnel awareness of historic resource stewardship as a key part

of the Army mission, including sustaining an annual Army historic preservation awards program to recognize

installation management excellence, innovation, and partnership. 

Department of the Interior, Bureau of Land Management

■ BLM should adopt and follow the recommendations contained in its staff paper, “Strategic Paper on Cultural Resourc e s

at Risk” (June 2000), including those recommending awards recognition; upper management support; evaluating and

establishing appropriate budget allocation strategies; priorities for “at risk” re s o u rces; assembling more complete 

p rogram statistics; developing a cultural training module; and balancing proactive work with Section 106 reviews. 

■ BLM should seek additional funding for cultural re s o u rce programs to support adequate professional staff and

enable it to plan and carry out specific protection and development strategies for significant threatened re s o u rc e s .

■ Funding for cultural resources activities should be specifically provided for in the budget process in such a way

that multi-year preservation activities, as well as interdisciplinary resource management planning, can more

fairly compete for appropriations.

■ Given the extent of its holdings and overlapping interests, BLM should place a high priority on joint projects

with the Forest Service and other Federal agencies within the Department of Interior, as well as with the

Department of Defense, to take advantage of economies of scale, cost-share area interpretive and educational

programs, and cooperate in collecting and sharing data on historic resources.

■ BLM should undertake greater eff o rts to support public-private partnerships in protection eff o rts through 

challenge grants and other seed money, including creative use of Recreation Fee Demonstration money. It should

also take maximum advantage of the important contributions now being made by private volunteers in site protection programs (such as Arizona’s highly successful Site Stewards program) and in inventory, stabilization, and

i n t e r p retation programs (such as the national Passport in Time pro g r a m ) .

■ A high priority should be placed on proactive steps to inventory and evaluate BLM resources, consistent with

recent findings of the Office of Inspector General of the Department of the Interior, and consistent with some

successful prototype efforts in National Forests in the Sierra Nevada area of California. Such efforts should

benefit from a grand design (if possible, at a multi-State or regional level) and/or integrated planning approach,

rather than the current, predominantly piecemeal, project-driven survey efforts. Such inventory and evaluation

work should be developed and priorities set in consultation with State Historic Preservation Officers and

Indian tribes, and should place primary emphasis on gaining a better understanding of the quality, significance,

and condition of historic resources rather than simply on locational and quantitative analysis.

■ Law enforcement efforts to protect sites from vandalism should be increased and targeted to especially critical

areas, again with assistance from a broad range of private and public partners.

■ A means for building upon and learning from the most successful public interpretation programs and sharing

model approaches with the Forest Service and the National Park Service should be pursued, particularly for

interpreting the historic resources within special management areas such as national monuments.

Appendix 1 Continued
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Department of Agriculture, U.S. Forest Service

■ The Forest Service should adopt and follow the recommendations contained in its staff paper, “Heritage—It’s About

Time! A National Strategy” (September 1999), as well as adopt the following implementation strategies: 

— gain the commitment of the Recreation, Heritage, and Wi l d e rness Resource leadership to make the heritage

vision a shared vision; 

— develop a communications plan to heighten the awareness of Forest Service leadership, the Department of

A g r i c u l t u re, and Congress re g a rding the untapped opportunities and public benefits of the heritage program; 

— assess the national heritage program funding level in terms of the Forest Service’s ability to implement the

strategy and the benefits to be derived, and making adjustments; 

— implement a plan to provide the heritage workforce the training, tools, and resources needed to make the

strategy a reality; and 

— begin to forge alliances with other agencies, local communities, tribes, private sector partners, the 

professional community, and others whose cooperation and support are needed to achieve the vision. 

■ The Department of Agriculture and the Forest Service should seek additional funding for cultural re s o u rce 

p rograms to support adequate professional staff and enable it to plan and carry out specific protection and

development strategies for significant threatened re s o u rc e s .

■ Funding for cultural resources activities should be specifically provided for in the budget process in such a way

that multi-year preservation activities, as well as interdisciplinary resource management planning, can more

fairly compete for appropriations.

■ Given the extent of its holdings and overlapping interests, the Forest Service should place a high priority on

joint projects with the Bureau of Land Management and other Federal agencies within the Department of the

Interior, as well as with the Department of Defense, to take advantage of economies of scale, to cost-share area

interpretive and educational programs, and to cooperate in collecting and sharing data on historic resources.

■ The Forest Service should undertake greater eff o rts to support public-private partnerships in protection eff o rt s

t h rough challenge grants and other seed money, including creative use of Recreation Fee Demonstration money.

It should also take maximum advantage of the important contributions now being made by private volunteers

in site protection programs (such as Arizona’s highly successful Site Stewards program) and in inventory, 

stabilization, and interpretation programs (such as the national Passport in Time pro g r a m ) .

■ A high priority should be placed on proactive steps to inventory and evaluate Forest Service re s o u rces, consistent

with some successful prototype eff o rts in National Forests in the Sierra Nevada area of California. Such eff o rt s

should benefit from a grand design (if possible, at a multi-State or regional level) and/or integrated planning

a p p roach, rather than the current predominant piecemeal, project driven survey eff o rts. Such inventory and evaluation work should be developed and priorities set in consultation with State Historic Pre s e rvation Officers and

Indian tribes, and should place primary emphasis on gaining a better understanding of the quality, significance, and

condition of historic and cultural re s o u rces rather than simply on locational and quantitative analysis.

■ Law enforcement efforts to protect sites from vandalism should be increased and targeted to especially critical

areas, again with assistance from a broad range of private and public partners.

■ A means for expanding, building upon, and learning from the most successful public interpretation programs

and sharing model approaches with the BLM and the National Park Service should be pursued, particularly

for interpreting the historic resources within special management areas such as national monuments.

Appendix 1 Continued
C A R I N G F O R T H E P A S T M A N A G I N G F O R T H E F U T U R E

A P P E N D I C E S

8 5

Appendix 2

POLICY, BUDGET, AND STRATEGIC PLANNING INITIATIVES RELATED TO HISTORIC

RESOURCES STEWARDSHIP BEGUN BY AGENCIES DURING THE COURSE OF THIS

STUDY 

Department of Agriculture, U.S. Forest Service

Recreation Summit (October 1999)

“Heritage—It’s About Time! A National Strategy” (September 1999) 

Department of Defense, Department of the Army

Army Residential Communities Initiative (no date)

Managing the Army’s Historic Properties: A Blueprint for Preservation and Reuse (no date)

Department of Energy

Corporate Board on Historic Preservation (formed October 1998; first report January 2000) 

Department of the Interior, Bureau of Land Management

“Strategic Paper on Cultural Resources at Risk” (June 2000) 

Department of the Interior, National Park Service

Federal Preservation Institute initiative (September 2000)

“Cultural Resources Challenge: The National Park Service’s Action Plan for Preserving Cultural Resources” 

(draft; September 2000)

General Services Administration

Held in Public Trust: PBS Strategy for Using Public Buildings (May 1999)
A D V I S O R Y C O U N C I L O N H I S T O R I C P R E S E R V A T I O N

A P P E N D I C E S

8 6

Appendix 3

OTHER RECENT INITIATIVES: AMERICA’S TREASURES, LEGACY, AND “MY HISTORY”

R e c e n t l y, several noteworthy initiatives were created to raise awareness and funding for pre s e rving some of the Nation’s

most important historic artifacts and pro p e rties. One of these is a national eff o rt to promote and protect a variety of

historic tre a s u res; a second initiative of longer duration is internal to the Department of Defense; and a third is dire c ted at pre s e rving personal history and community heritage. The three initiatives are instructive and offer suggestions

about how relatively small amounts of funding might be used in a focused and effective way for these purposes. 

With assistance and encouragement from former First Lady Hillary Clinton and the White House Millennium Council, a

number of important eff o rts are being pursued under the theme, “Honor the Past, Imagine the Future.” The Save America’s

Tre a s u re s initiative is advancing this theme with a four- p ronged campaign to 1) foster pride in American heritage; 2) educate Americans on pre s e rvation problems facing the buildings, sites, monuments, objects, and documents that re p re s e n t

A m e r i c a ’s diverse cultural legacy; 3) raise concern for the urgent pre s e rvation needs of this country ’s historic tre a s u res; and

4) stimulate broad-scale involvement in these campaigns, including securing necessary re s o u rces and support, org a n i z a t i o n

of grassroots pre s e rvation projects, participation in community pre s e rvation, and educational initiatives.

Save America’s Treasures has two major components: a Federal fund administered by the National Park Service to

help support preservation of nationally significant resources; and a private fund-raising effort advanced by the

National Trust for Historic Preservation, in partnership with the National Park Foundation and Heritage

Preservation. In 1999, $30 million was awarded to 62 projects in 24 states, the District of Columbia, and Midway

Islands, and $15 million was available in 2000. In 2001, $35 million has been appropriated. More than $40 million

has been raised to date from the private sector.

A second major initiative, the Department of Defense Legacy Resource Management Program, was established under

the Department of Defense Appropriations Act in 1991. Legacy, a major program involving dedicated funding to support cultural and natural resource management, has enjoyed and continues to enjoy bipartisan support. Begun at an

appropriation level of $10 million (including both natural and cultural resources), the program’s funding reached a

high of $50 million in the three consecutive years of FY 1993-1995. It is currently funded at $15 million, and $12

million was requested for FY 2001. In the past four fiscal years alone, DoD has received $45 million, with probably

about 40 percent of that amount being spent on historic resource concerns and 60 percent on natural resources.

A third initiative, My History is America’s History, is being advanced by the National Endowment for the Humanities,

with assistance from the Pre s i d e n t ’s Committee on the Arts and Humanities, the Department of Education, several

genealogy organizations and publishing companies, and the National Association of Broadcasters. My History has published a handbook on pre s e rving family history, and has established a Web site that is intended to serve as a virt u a l

“ f ront porch” for those who want to learn more about their own history and the history of others. Teachers across the

c o u n t ry are being encouraged to use family history to engage their students more broadly about American history.
C A R I N G F O R T H E P A S T 8 7 M A N A G I N G F O R T H E F U T U R E

Information for this report was gathered from a variety of sources. Ideas from a broad range of organizations and

individuals was solicited on the future of Federal historic preservation via the Council’s Web site, through a discussion forum established especially for the Millennium initiative. The Internet forum was online from February 1999

until September 2000.

Regular meetings of the Council were devoted in part to focused examination and discussion of critical issues connected with the Federal Government’s role in historic preservation. The six meetings in this series were held in Santa

Fe and Los Alamos, New Mexico (November 1998), Honolulu, Hawaii (February 1999), Washington, DC (June

1999), Oak Ridge and Great Smoky Mountains, Tennessee (November 1999), Phoenix, Arizona (March 2000), and

Portland, Maine (June 2000).

In addition, Council members and staff made formal presentations at the Statewide Pre s e rvation Org a n i z a t i o n s

Annual Meeting in Honolulu, Hawaii (Febru a ry 1999), the Annual Meeting of the National Conference of State

Historic Pre s e rvation Officers in Washington, DC (March 1999), and the National Trust for Historic

P re s e rv a t i o n ’s Annual Pre s e rvation Conference in Washington, DC (October 1999). They also participated in

special agency conferences and meetings on historic pre s e rvation and cultural re s o u rce management thro u g h o u t

the period. 

A Council member Task Force on the Millennium provided policy oversight for the project, and the Council’s

p rofessional staff conducted this study in consultation with that task force and other parties as indicated on the

p receding pages. 

This study has been published in two parts. Single copies of both the special illustrated summary version of the

report, and this full report, with references, examples, and additional explanatory material, may be requested from

the Council. This full report is also available on the Council’s Web site at www.achp.gov.

N O T E S O N T H I S S T U D Y


THE AD VISORY COUNCIL ON HISTORIC PRES ERVAT I O N

1100 PENNSY LVANIA AVENUE , NW – SUITE 809

WAS HIN GTON, DC 2 0004

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