National Park Service: A More Systematic Process for Establishing National Heritage Areas and Actions to Improve Their Accountability Are Needed
Published: 2004-03-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Congress has established, or "designated," 24 national heritage areas to recognize the value of their local traditions, history, and resources to the nation's heritage. These areas, including public and private lands, receive funds and assistance through cooperative agreements with the National Park Service, which has no formal program for them. They also receive funds from other agencies and nonfederal sources, and are managed by local entities. Growing interest in new areas has raised concerns about rising federal costs and the risk of limits on private land use. GAO was asked to review the (1) process for designating heritage areas, (2) amount of federal funding to these areas, (3) process for overseeing areas' activities and use of federal funds, and (4) effects, if any, they have on private property rights.
section_title: What GAO Found
paragraphs: No systematic process currently exists for identifying qualified sites and designating them as national heritage areas. While the Congress generally has designated heritage areas with the Park Service's advice, it designated 10 of the 24 areas without a thorough agency review; in 6 of these 10 cases, the agency recommended deferring action. Even when the agency fully studied sites, it found few that were unsuitable. The agency's criteria are very general. For example, one criterion states that a proposed area should reflect "traditions, customs, beliefs, and folk life that are a valuable part of the national story." These criteria are open to interpretation and, using them, the agency has eliminated few sites as prospective heritage areas. According to data from 22 of the 24 heritage areas, in fiscal years 1997 through 2002, the areas received about $310 million in total funding. Of this total, about $154 million came from state and local governments and private sources and another $156 million came from the federal government. Over $50 million was dedicated heritage area funds provided through the Park Service, with another $44 million coming from other Park Service programs and about $61 million from 11 other federal sources. Generally, each area's designating legislation imposes matching requirements and sunset provisions to limit the federal funds. However, since 1984, five areas that reached their sunset dates had their funding extended. The Park Service oversees heritage areas' activities by monitoring their implementation of the terms set forth in the cooperative agreements. These terms, however, do not include several key management controls. That is, the agency has not (1) always reviewed areas' financial audit reports, (2) developed consistent standards for reviewing areas' management plans, and (3) developed results-oriented goals and measures for the agency's heritage area activities, or required the areas to adopt a similar approach. Park Service officials said that the agency has not taken these actions because, without a program, it lacks adequate direction and funding. Heritage areas do not appear to have affected property owners' rights. In fact, the designating legislation of 13 areas and the management plans of at least 6 provide assurances that such rights will be protected. However, property rights advocates fear the effects of provisions in some management plans. These provisions encourage local governments to implement land use policies that are consistent with the heritage areas' plans, which may allow the heritage areas to indirectly influence zoning and land use planning in ways that could restrict owners' use of their property. Nevertheless, heritage area officials, Park Service headquarters and regional staff, and representatives of national property rights groups that we contacted were unable to provide us with any examples of a heritage area directly affecting--positively or negatively--private property values or use.

section_title: Letter
paragraphs: I am pleased to be here today to discuss a number of issues concerning the  designation, funding, and oversight of national heritage areas. As you  know, over the past two decades, the Congress has established, or  “designated,” 24 national heritage areas and provided them with millions  of dollars in financial assistance through the National Park Service. By  providing this designation, the Congress has determined that these areas’  local cultures, traditions, history, and resources are worthy of being  recognized and preserved because of their contributions to the nation’s  heritage. These areas can encompass large tracts of land and incorporate  public as well as private property. The number of bills introduced to study  or designate new areas has grown considerably in recent years. In the  108th Congress alone, as of early March 2004, over 30 bills had been  introduced to either study or establish new areas. This growing interest in  creating new heritage areas has raised concerns that their numbers may  expand rapidly and significantly increase the amount of federal funds  supporting them. In addition, private property rights advocates are  concerned that heritage area designations could increase the risk that  federal controls or other limits will be placed on private land use.
Once designated, heritage areas can receive funding through the National  Park Service’s budget, although the agency has no formal heritage area  program. The Park Service provides technical assistance to the areas, and  the Congress appropriates the agency limited funds for these activities.  The Park Service allocates funding to the areas through cooperative  agreements. These funds are considered to be “seed” money to assist each  area in becoming sufficiently established to develop partnerships with  state and local governments, businesses, and other nonfederal  organizations as their principal funding sources. Heritage areas also  receive funds from other federal agencies through a variety of programs,  primarily the Department of Transportation for road and infrastructure  improvements.
In this context, my testimony today focuses on the results of our work on  national heritage areas conducted at the request of this Committee.
Specifically, it addresses the (1) process for identifying and designating  national heritage areas, (2) amount of federal funding provided to support  these areas, (3) process for overseeing and holding national heritage areas  accountable for their use of federal funds, and (4) extent to which, if at all,  these areas have affected private property rights.
To address these issues, we obtained information on the Park Service’s  heritage area activities from the Heritage Area national coordinator and  program managers in the four Park Service regions that include heritage  areas. We also obtained funding information from 22 of the 24 existing  areas for fiscal years 1997 through 2002, and discussed this information  with the executive directors and staff of each area. In addition, we visited  8 of the 24 heritage areas to view their operations and accomplishments,  and discussed various issues with their executive directors. Finally, we  discussed concerns about private property rights with representatives of  several organizations advocating property rights. We conducted our work  between May 2003 and March 2004 in accordance with generally accepted  government auditing standards. A more complete description of our  methodology is included in app. I.
subsections: section_title: Background
paragraphs: To date, the Congress has designated 24 national heritage areas, primarily  in the eastern half of the country (see fig. 1).
Generally, national heritage areas focus on local efforts to preserve and  interpret the role that certain sites, events, and resources have played in  local history and their significance in the broader national context. For  example, the Rivers of Steel Heritage Area commemorates the  contribution of southwestern Pennsylvania to the development of the  nation’s steel industry by providing visitors with interpretive tours of  historic sites and other activities. Heritage areas share many similarities— such as recreational resources and historic sites—with national parks and  other park system units but lack the stature and national significance to  qualify them as these units.
The process of becoming a national heritage area usually begins when  local residents, businesses, and governments ask the Park Service, within  the Department of the Interior, or the Congress for help in preserving their  local heritage and resources. In response, although the Park Service has  no program governing these activities, the agency provides technical  assistance, such as conducting or reviewing studies to determine an area’s  eligibility for heritage area status. The Congress then may designate the  site as a national heritage area and set up a management entity for it. This  entity could be a state or local governmental agency, an independent  federal commission, or a private nonprofit corporation. Usually within 3  years of designation, the area is required to develop a management plan,  which is to detail, among other things, the area’s goals and its plans for  achieving those goals. The Park Service then reviews these plans, which  must be approved by the Secretary of the Interior.
After the Congress designates a heritage area, the Park Service enters into  a cooperative agreement with the area’s management entity to assist the  local community in organizing and planning the area. Each area can  receive funding through the Park Service’s budget—generally limited to  not more than $1 million a year for 10 or 15 years. The agency allocates the  funds to the area through the cooperative agreement.
section_title: No Systematic Process Exists for Identifying and Designating National Heritage Areas
paragraphs: No systematic process is in place to identify qualified candidate sites and  designate them as national heritage areas. In this regard, the Park Service  conducts studies—or reviews studies prepared by local communities—to  evaluate the qualifications of sites proposed for national heritage  designation. On the basis of these studies, the agency advises the Congress  as to whether a particular location warrants designation. The agency  usually provides its advice to the Congress by testifying in hearings on  bills to authorize a particular heritage area. The Park Services’ studies of  prospective sites’ suitability help the agency ensure that the basic  components necessary to a successful heritage area—such as natural and  cultural resources and community support—are either already in place or  are planned. Park Service data show that the agency conducted or  reviewed some type of study addressing the qualifications of all 24  heritage areas. However, in some cases, these studies were limited in  scope so that questions concerning the merits of the location persisted  after the studies were completed. As a result, the Congress designated 10  of the 24 areas with only a limited evaluation of their suitability as heritage  areas. Of these 10 areas, the Park Service opposed or suggested that the  Congress defer action on 6, primarily because of continuing questions  about, among other issues, whether the areas had adequately identified  goals or management entities or demonstrated community support.  Furthermore, of the 14 areas that were designated after a full evaluation,  the Congress designated 8 consistent with the Park Service’s  recommendations, 5 without the agency’s advice, and 1 after the agency  had recommended that action be deferred.
Furthermore, the criteria the Park Service uses to evaluate the suitability  of prospective heritage areas are not specific and, in using them, the  agency has determined that a large portion of the sites studied qualify as  heritage areas. According to the Heritage Area national coordinator,  before the early 1990s, the Park Service used an ad hoc approach to  determining sites’ eligibility as heritage areas, with little in the way of  objective criteria as a guide. Since then, however, the Park Service  developed general guidelines to use in evaluating and advising the  Congress on the suitability of sites as heritage areas. Based on these  guidelines, in 1999, the agency developed a more formal approach to  evaluating sites. This approach consisted of four actions that the agency  believed were critical before a site could be designated as well as 10  criteria to be considered when conducting studies to assess an area’s  suitability.
The four critical steps include the following:    complete a suitability/feasibility study;  involve the public in the suitability/feasibility study;   demonstrate widespread public support for the proposed designation; and    demonstrate commitment to the proposal from governments, industry,   and private, nonprofit organizations.
A suitability/feasibility study, should examine a proposed area using the  following criteria:    The area has natural, historic, or cultural resources that represent  distinctive aspects of American heritage worthy of recognition,  conservation, interpretation, and continuing use, and are best managed  through partnerships among public and private entities, and by combining  diverse and sometimes noncontiguous resources and active communities;   The area’s traditions, customs, beliefs, and folk life are a valuable part of  the national story;   The area provides outstanding opportunities to conserve natural, cultural,  historic, and/or scenic features;   The area provides outstanding recreational and educational opportunities;    Resources that are important to the identified themes of the area retain a  degree of integrity capable of supporting interpretation;   Residents, businesses, nonprofit organizations, and governments within  the area that are involved in the planning have developed a conceptual  financial plan that outlines the roles for all participants, including the  federal government, and have demonstrated support for designation of the  area;   The proposed management entity and units of government supporting the  designation are willing to commit to working in partnership to develop the  area;   The proposal is consistent with continued economic activity in the area;    A conceptual boundary map is supported by the public; and    The management entity proposed to plan and implement the project is  described.
These criteria are broad and subject to multiple interpretations, as noted  by an official in the agency’s Midwest region charged with applying these  criteria to prospective areas. Similarly, according to officials in the  agency’s Northeast region, they believe that the criteria were developed to  be inclusive and that they are inadequate for screening purposes. The  national coordinator believes, however, that the criteria are valuable but  that the regions need additional guidance to apply them more consistently.  The Park Service has developed draft guidance for applying these criteria  but has no plans to issue them as final guidance. Rather, the agency is  incorporating this guidance into a legislative proposal for a formal heritage  area program. According to the national coordinator, some regions have  used this guidance despite its draft status, but it has not been widely  adopted or used to date.
The Park Service’s application of these broad criteria has identified a large  number of potential heritage areas. Since 1989, the Park Service has  determined that many of the candidate sites it has evaluated would qualify  as national heritage areas.
section_title: National Heritage Areas Annually Receive Millions in Federal Funding
paragraphs: According to data from 22 of the 24 heritage areas, about half of their total  funding of $310 million in fiscal years 1997 through 2002 came from the  federal government and the other half from state and local governments  and private sources. Table 1 shows the areas’ funding sources from fiscal  years 1997 through 2002.
As figure 2 shows, the federal government’s total funding to these heritage  areas increased from about $14 million in fiscal year 1997 to about $28  million in fiscal year 2002, peaking at over $34 million in fiscal year 2000.
The Congress sets the overall level of funding for heritage areas,  determining which areas will receive funding and specifying the amounts  provided. Newly designated heritage areas usually receive limited federal  funds while they develop their management plans and then receive  increasing financial support through Park Service appropriations after  their plans are established. The first heritage areas received pass-through  grants from the Park Service and funding through the agency’s Statutory  and Contractual Aid appropriations. However, in 1998, the Congress began  appropriating funds to support heritage areas through the Heritage  Partnership Program.
In addition, the Congress has placed in each area’s designating legislation  certain conditions on the receipt of federal funds. While the legislation  designating the earliest heritage areas resulted in different funding  structures, generally those created since 1996 have been authorized  funding of up to $10 million over 15 years, not to exceed $1 million in any  single year. In conjunction with this limit, the designating legislation  attempts to identify a specific date when heritage areas no longer receive  federal financial or technical assistance. Although heritage areas are  ultimately expected to become self-sufficient without federal support, to  date the sunset provisions have not limited federal funding. Since the first  national heritage area was designated in 1984, five have reached the sunset  date specified in their designating legislation. However, in each case, the  sunset date was extended and the heritage area continued to receive  funding from the Congress.
Finally, the areas’ designating legislation typically requires the heritage  areas to match the amount of federal funds they receive with a specified  percentage of funds from nonfederal sources. Twenty-two of the 24  heritage areas are required to match the federal funds they receive. Of  these 22 areas, 21 have a 50-percent match requirement—they must show  that at least 50 percent of the funding for their projects has come from  nonfederal sources—and one has a 25-percent match requirement.
section_title: The Park Service Lacks an Effective Process for Ensuring that National Heritage Areas Are Accountable for Their Use of Federal Funds
paragraphs: In the absence of a formal program, the Park Service oversees heritage  areas’ activities by monitoring the implementation of the terms set forth in  the cooperative agreements. According to Park Service headquarters  officials, the agency’s cooperative agreements with heritage areas allow  the agency to effectively oversee their activities and hold them  accountable. These officials maintain that they can withhold funds from  heritage areas—and have, in some circumstances, done so—if the areas  are not carrying out the requirements of the cooperative agreements.  However, regional managers have differing views on their authority for  withholding funds from areas and the conditions under which they should  do so.
Although Park Service has oversight opportunities through the  cooperative agreements, it has not taken advantage of these opportunities  to help to improve oversight and ensure these areas’ accountability. In this  regard, the agency generally oversees heritage areas’ funding through  routine monitoring and oversight activities, and focuses specific attention  on the areas’ activities only when problems or potential concerns arise.  However, the Park Service regions that manage the cooperative  agreements with the heritage areas do not always review the areas’ annual  financial audit reports, although the agency is ultimately the federal  agency responsible for heritage area projects that are financed with  federal funds. For example, managers in two Park Service regions told us  that they regularly review heritage areas’ annual audit reports, but a  manager in another region said that he does not. As a result, the agency  cannot determine the total amount of federal funds provided or their use.  According to these managers, the inconsistencies among regions in  reviewing areas’ financial reports primarily result from a lack of clear  guidance and the collateral nature of the Park Service regions’ heritage  area activities—they receive no funding for oversight, and their oversight  efforts divert them from other mission-critical activities.
Furthermore, the Park Service has not yet developed clearly defined,  consistent, and systematic standards and processes for regional staff to  use in reviewing the adequacy of areas’ management plans, although these  reviews are one of the Park Service’s primary heritage area  responsibilities. Heritage areas’ management plans are blueprints that  discuss how the heritage area will be managed and operated and what  goals it expects to achieve, among other issues. The Secretary of the  Interior must approve the plans after Park Service review. According to  the national coordinator, heritage area managers in the agency’s Northeast  region have developed a checklist of what they consider to be the  necessary elements of a management plan to assist reviewers in evaluating  the plans. While this checklist has not been officially adopted, managers in  the Northeast and other regions consult it in reviewing plans, according to  the national coordinator. Heritage area managers in the Park Service  regions use different criteria for reviewing these plans, however. For  example, managers in the regions told us that, to judge the adequacy of the  plans, one region uses the specific requirements in the areas’ designating  legislation, another uses the designating legislation in conjunction with the  Park Service’s general designation criteria, and a third adapts the process  used for reviewing national park management plans. While these  approaches may guide the regions in determining the content of the plans,  they provide little guidance in judging the adequacy of the plans for  ensuring successful heritage areas.
Finally, the Park Service has not yet developed results-oriented  performance goals and measures—consistent with the requirements of the  Government Performance and Results Act—that would help to ensure the  efficiency and effectiveness of its heritage area activities. The act requires  agencies to, among other actions, set strategic and annual goals and  measure their performance against these goals. Effectively measuring  performance requires developing measures that demonstrate results,  which, in turn, requires data. According to the national coordinator, the  principal obstacles to measuring performance are the difficulty of  identifying meaningful indicators of success and the lack of funding to  collect the needed data. With regard to indicators, the national coordinator  told us that the agency has tried to establish meaningful and measurable  goals both for their activities and the heritage areas. The agency has  identified a series of “output” measures of accomplishment, such as  numbers of heritage areas visitors, formal and informal partners,  educational programs managed, and grants awarded. However, the  national coordinator acknowledged that these measures are insufficient,  and the agency continues to pursue identifying alternative measures that  would be more meaningful and useful. However, without clearly defined  performance measures for its activities, the agency will continue to be  unable to effectively gauge what it is accomplishing and whether its  resources are being employed efficiently and cost-effectively.
The Park Service also has not required heritage areas to adopt a results- oriented management approach—linked to the goals set out in their  management plans—which would enable both the areas and the agency to  determine what is being accomplished with the funds that have been  provided. In this regard, the heritage areas have not yet developed an  effective, outcome-oriented method for measuring their own performance  and are therefore unable to determine what benefits the heritage area— and through it, the federal funds—have provided to the local community.  For example, for many heritage areas, increasing tourism is a goal, but  while they may be able to measure an increase in tourism, they cannot  demonstrate whether this increase is directly associated with the efforts of  the heritage area. To address these issues, the Alliance of National  Heritage Areas is currently working with Michigan State University to  develop a way to measure various impacts associated with a national  heritage area. These impacts include, among others, the effects on tourism  and local economies through jobs created and increases in tax revenues.
According to Park Service officials, the agency has not taken actions to  improve oversight because, without a formal program, it does not have the  direction or funding it needs to effectively administer its national heritage  area activities.
section_title: National Heritage Areas Do Not Appear to Have Affected Individual Property Rights
paragraphs: National heritage areas do not appear to have affected private property  rights, although private property rights advocates have raised a number of  concerns about the potential effects of heritage areas on property owners’  rights and land use. These advocates are concerned that heritage areas  may be allowed to acquire or otherwise impose federal controls on  nonfederal lands. However, the designating legislation and the  management plans of some areas explicitly place limits on the areas’  ability to affect private property rights and use. In this regard, eight areas’  designating legislation stated that the federal government cannot impose  zoning or land use controls on the heritage areas. Moreover, in some  cases, the legislation included explicit assurances that the areas would not  affect the rights of private property owners. For example, the legislation  creating 13 of the 24 heritage areas stated that the area’s managing entity  cannot interfere with any person’s rights with respect to private property  or have authority over local zoning ordinances or land use planning. While  management entities of heritage areas are allowed to receive or purchase  real property from a willing seller, under their designating legislation, most  areas are prohibited from using appropriated funds for this purpose. In  addition, the designating legislation for five heritage areas requires them to  convey the property to an appropriate public or private land managing  agency.
As a further protection of property rights, the management plans of some  heritage areas deny the managing entity authority to influence zoning or  land use. For example, at least six management plans state that the  managing entities have no authority over local zoning laws or land use  regulations. However, most of the management plans state that local  governments’ participation will be crucial to the success of the heritage  area and encourage local governments to implement land use policies that  are consistent with the plan. Some plans offer to aid local government  planning activities through information sharing or technical or financial  assistance to achieve their cooperation. Property rights advocates are  concerned that such provisions give heritage areas an opportunity to  indirectly influence zoning and land use planning, which could restrict  owners’ use of their property. Some of the management plans state the  need to develop strong partnerships with private landowners or  recommend that management entities enter into cooperative agreements  with landowners for any actions that include private property.
Despite concerns about private property rights, officials at the 24 heritage  areas, Park Service headquarters and regional staff working with these  areas, and representatives of six national property rights groups that we  contacted were unable to provide us with a single example of a heritage  area directly affecting—positively or negatively—private property values  or use.
section_title: Conclusions
paragraphs: National heritage areas have become an established part of the nation’s  efforts to preserve its history and culture in local areas. The growing  interest in establishing additional areas will put increasing pressure on the  Park Service’s resources, especially since the agency receives limited  funding for the technical and administrative assistance it provides to these  areas. Under these circumstances, it is important to ensure that only those  sites’ that are most qualified are designated as heritage areas. However, no  systematic process for designating these areas exists, and the Park Service  does not have well-defined criteria for assessing sites’ qualifications or  effective oversight of the areas’ use of federal funds and adherence to their  management plan. As a result, the Congress and the public cannot be  assured that future sites will have the necessary resources and local  support needed to be viable or that federal funds supporting them will be  well spent.
Given the Park Service’s resource constraints, it is important to ensure  that the agency carries out its heritage area responsibilities as efficiently  and effectively as possible. Park Service officials pointed to the absence of  a formal program as a significant obstacle to effective management of the  agency’s heritage area efforts and oversight of the areas’ activities. In this  regard, without a program, the agency has not developed consistent  standards and processes for reviewing areas’ management plans, the areas’  blueprints for becoming viable and self-sustaining. It also has not required  regional heritage area managers to regularly and consistently review the  areas’ annual financial audit reports to ensure that the Park Service—the  agency with lead responsibility for these areas—has complete information  on their use of funds from all federal agencies as a basis for holding them  accountable. Finally, the Park Service has not defined results-oriented  performance goals and measures—both for its own heritage area efforts  and those of the individual areas. As a result, it is constrained in its ability  to determine both the agency’s and areas’ accomplishments, whether the  agency’s resources are being employed efficiently and effectively, and if  federal funds could be better utilized to accomplish its goals.
section_title: Recommendations for Executive Action
paragraphs: In the absence of congressional action to establish a formal heritage area  program within the National Park Service or to otherwise provide  direction and funding for the agency’s heritage area activities, we  recommend that the Secretary of the Interior direct the Park Service to  take actions within its existing authority to improve the effectiveness of its  heritage area activities and increase areas’ accountability. These actions  should include    developing well-defined, consistent standards and processes for regional  staff to use in reviewing and approving heritage areas’ management plans; requiring regional heritage area managers to regularly and consistently  review heritage areas’ annual financial audit reports to ensure that the  agency has a full accounting of their use of funds from all federal sources,  and   developing results-oriented performance goals and measures for the  agency’s heritage area activities, and requiring, in the cooperative  agreements, heritage areas to adopt such a results-oriented management  approach as well.
Thank you, Mr. Chairman and Members of the Committee. This concludes  my prepared statement. I would be happy to respond to any questions that  you or Members of the Committee may have.
section_title: Contacts and Acknowledgments
paragraphs: For more information on this testimony, please contact Barry T. Hill at  (202) 512-3841. Individuals making key contributions to this testimony  included Elizabeth Curda, Preston S. Heard, Vincent P. Price, and Barbara  Timmerman.
section_title: Appendix I: Scope and Methodology
paragraphs: To examine the establishment, funding, and oversight of national heritage  areas and their potential effect on private property rights, we (1) evaluated  the process for identifying and designating national heritage areas, (2)  determined the amount of federal funding provided to support these areas,  (3) evaluated the process for overseeing and holding national heritage  areas accountable for their use of federal funds, and (4) determined the  extent to which, if at all, these areas have affected private property rights.
To address the first issue, we discussed the process for identifying and  designating heritage areas with the Park Service’s Heritage Area national  coordinator and obtained information on how the 24 existing heritage  areas were evaluated and designated. To determine the amount of federal  funding provided to support these areas, we discussed funding issues and  the availability of funding data with the national coordinator, the Park  Service’s Comptroller, and officials from the agency’s Northeast, Midwest,  Southeast, and Intermountain Regional Offices. We also obtained funding  information from 22 of the 24 heritage areas for fiscal years 1997 through  2002, and discussed this information with the executive directors and staff  of each area. As of mid-March 2004, two heritage areas had not provided  us with funding data. To verify the accuracy of the data we obtained from  these sources, we compared the data provided to us with data included in  the heritage areas’ annual audit and other reports that we obtained from  the individual areas and the Park Service regions. We also discussed these  data with the executive directors and other officials of the individual  heritage areas and regional office officials.
To evaluate the processes for holding national heritage areas accountable  for their use of federal funds, we discussed these processes with the  national coordinator and regional officials, and obtained information and  documents supporting their statements.
To determine the extent to which, if at all, private property rights have  been affected by these areas, we discussed this issue with the national  coordinator, regional officials, the Executive Director of the Alliance of  National Heritage Areas—an organization that coordinates and supports  heritage areas’ efforts and is their collective interface with the Park  Service—the executive directors of the 23 heritage areas that were  established at the time of our work, and representatives of several private  property rights advocacy groups and individuals, including the American  Land Rights Association, the American Policy Center, the Center for  Private Conservation, the Heritage Foundation, the National Wilderness  Institute, and the Private Property Foundation of America. In each of these  discussions, we asked the individuals if they were aware of any cases in  which a heritage area had positively or negatively affected an individual’s  property rights or restricted its use. None of these individuals were able to  provide such an example.
In addition, we visited the Augusta Canal, Ohio and Erie Canal, Rivers of  Steel, Shenandoah Valley Battlefields, South Carolina, Southwestern  Pennsylvania (Path of Progress), Tennessee Civil War, and Wheeling  National Heritage Areas to discuss these issues in person with the areas’  officials and staff, and to view the areas’ features and accomplishments  first hand.
We conducted our work between May 2003 and March 2004 in accordance  with generally accepted government auditing standards.
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