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Proposed changes to regulations governing the listing of properties in the National Register of Historic Places

  • 1.  Proposed changes to regulations governing the listing of properties in the National Register of Historic Places

    Posted 03-20-2019 09:41
    The National Park Service is asking for public comments on a proposed rule change to revise regulations governing the listing of properties in the National Register of Historic Places. Most of these changes seem rather minor except for the way that "votes" are counted if property owners object to an NR listing. So far, there's only 7 comments on the site. You have until 11:59 p.m. EST on April 30, 2019 to leave your own comments as well

    Any thoughts on the magnitude of these changes? Is this all pretty ho-hum or am I missing something here? What about the changes to how a federal agency can directly submit a nomination. What "problem" is being solved here? (For some more background on what's driving this rule change, here is the 2016 National Park Service Centennial Act.)

    Also, of note, the Advisory Council on Historic Preservation will be discussing this rule change in their public meeting on Thursday, April 4, 2019 at 8:30 a.m.

    -Jeremy




  • 2.  RE: Proposed changes to regulations governing the listing of properties in the National Register of Historic Places

    Ambassador
    Posted 03-22-2019 12:07
    Jeremy,

    Although I am a self-professed preservation policy nerd, I haven't had a chance to review this proposed language yet. The number of comments is now up to 17 (you have to click on the comment bubbles to see the actual number, as the front page still shows just 7).

    I suspect part of the impetus is a recent district nomination effort in Oregon. Search for articles and websites related to Eastmoreland in Portland. I do not know all of the issues on that nomination, but it did reach into congressional subcommittee hearings a year or two ago. I can also attest as a former SHPO staffer that determining ownership numbers on historic district nominations is a critical part of the nomination process that can become quite messy depending on numbers and types of ownership.

    My gut is telling me that adding in a complexity such as the size of parcels is concerning not just from a technical standpoint but from an equity standpoint. Maybe I'll feel differently when I have time to study the proposal. I'm interested to see how others feel about this issue.

    Barbara

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    Barbara Howard
    Stonebridge Learning, LLC
    Minneapolis MN
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  • 3.  RE: Proposed changes to regulations governing the listing of properties in the National Register of Historic Places

    Posted 03-25-2019 12:08
    Hi Jeremy -

    Thanks for starting this thread. The Trust is working on a blog post for Forum on this topic and hopes to provide some suggestions to help people who want to submit comments. The implications of the proposed rule change are both subtle and a bit complex, but we should have some information up soon. Looking forward to hearing what others have to say.

    Thanks,

    Sharee

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    Sharee Williamson
    Alexandria VA
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  • 4.  RE: Proposed changes to regulations governing the listing of properties in the National Register of Historic Places

    Ambassador
    Posted 03-28-2019 09:26
    Having lived in Portland at the time these issues were coming to a head, I will confirm that several of these changes seem very tailored to the Eastmoreland situation. I don't think these proposals necessarily solve the problem or are the best solution.

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    Tim Askin
    City of Milwaukee Historic Preservation Commission
    Milwaukee WI
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  • 5.  RE: Proposed changes to regulations governing the listing of properties in the National Register of Historic Places

    Posted 03-26-2019 09:58
    Hi, Jeremy,

    Thanks for bringing this up. A few things to look at when reading the proposed rule changes are (1) they extend beyond the language of the actual NRHP 2016 amendment and (2) there are potential consequences linked to
    • (a) taking into account the amount of land each owner holds in a potential historic district (whoever owns the most land has more of a say in whether a nomination moves forward to NPS for listing rather than the current system of one person = one vote);
    • (b) no longer requiring owners to get their objections notarized  (which is how SHPOs currently try to ensure that only the legal owner of a particular property gets a vote in a nomination); and
    • (c) requiring all steps to have been taken in the nomination of a property by a federal agency (including sending the nomination to NPS) prior to NPS hearing an appeal for a federal agency's failure to nominate a property.


    ------------------------------
    Laura Sadowsky
    State Historian
    State Historical Society of Iowa/State Historic Preservation Office
    Des Moines IA
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  • 6.  RE: Proposed changes to regulations governing the listing of properties in the National Register of Historic Places

    Posted 03-30-2019 20:44
    the amount of land one owner has will make a tremendous difference in the vote and if it will move forward.  Sometimes, a small project owned by a modest sharecropper, has more historical value than the vast ownership of land owned by one individual. The nomination of the modest will not move forward. It doesn't have a chance.


    --

    L Vannessa Frazier
    Executive Director
    Howardville Community Betterment
    Project Manager - City of Howardville - EPA Brownfield Cleanup Grant Award
    Robert Woods Johnson Foundation Culture of Health Leader - CoHort 1
    105 Howard Ave
    Howardville, Mo. 63869
    573-233-0926 - cell
    573-688-2137 - city hall - message
    573-688-5445 - fax
    newsonlydia@gmail.com

    CONFIDENTIALITY NOTICE: This communication contains information intended for the use of the individuals to whom it is addressed and may contain information that is privileged, confidential or exempt from other disclosure under applicable law. If you are not the intended recipient, you are notified that any disclosure, printing, copying, distribution or use of the contents is prohibited. If you have received this in error, please notify the sender immediately by telephone or by returning it via email and then permanently delete the communication from your system. Thank you.

     






  • 7.  RE: Proposed changes to regulations governing the listing of properties in the National Register of Historic Places

    Posted 03-29-2019 17:01
    For reference, the Living Landscape Observer newsletter just posted an analysis of the proposed rule change to the NR. Apparently, one of these changes would allow a federal agency to put a nomination of a federal property on hold for perpetuity, which could be abused for political ends.

    ------------------------------
    Jeremy Wells, Ph.D., Assistant Professor
    Historic Preservation Program, School of Architecture, Planning and Preservation, University of Maryland, College Park
    http://www.heritagestudies.org
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  • 8.  RE: Proposed changes to regulations governing the listing of properties in the National Register of Historic Places

    National Trust Advisor
    Posted 03-30-2019 07:09
    Jeremy and all,

    I'm concerned that this issue is not getting the serious attention I believe it deserves, and anxiously await the NTHP's advice and counsel.  Preservation Action made comments last week.  The comment period has 30 days remaining.

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    Pam O'Connor
    Michigan Advisor
    Kalamazoo MI
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  • 9.  RE: Proposed changes to regulations governing the listing of properties in the National Register of Historic Places

    Ambassador
    Posted 03-31-2019 17:24
    @Jeremy Wells thank you for sharing the Living Landscape Observer analysis. Preservation Action's assessment of the legislation can be found in their legislative update from March 22. If anyone reading this discussion thread is preparing comments, it may also help to review the other comments submitted thus far, especially the in-depth analysis outlined in the letter by Dr. Allyson Brooks, Washington's state historic preservation officer.


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    Barbara Howard
    Stonebridge Learning, LLC
    Minneapolis MN
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  • 10.  RE: Proposed changes to regulations governing the listing of properties in the National Register of Historic Places

    Posted 04-05-2019 15:05
    All. @Sharee Williamson and @Elizabeth Merritt wrote a piece for Forum with more analysis and a link to where you can comment. You can read the piece here.

    Please let us know if you have any questions.


    ​​​

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    Priya Chhaya
    Associate Director, Publications and Programs
    National Trust for Historic Preservation
    Washington DC
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  • 11.  RE: Proposed changes to regulations governing the listing of properties in the National Register of Historic Places

    Posted 6 days ago
    Thanks for the article! Have we heard any updates from the government as to the status of the proposed changes? Hopefully we were heard!

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    Daniel Levy
    Oakland CA
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  • 12.  RE: Proposed changes to regulations governing the listing of properties in the National Register of Historic Places

    Posted 6 days ago
    Hi Daniel - There’s been no formal update on this from NPS. However, after the April comment deadline passed, NPS did establish a new comment opportunity solely for tribes and held a consultation meeting at NCAI’s recent conference. We are continuing to monitor this issue and will update this blog post when we learn more.

    Sharee Williamson

    Sent from my iPhone




  • 13.  RE: Proposed changes to regulations governing the listing of properties in the National Register of Historic Places

    Posted 2 days ago
    thank you

    --

    L Vannessa Frazier
    Executive Director
    Howardville Community Betterment
    Project Manager - City of Howardville - EPA Brownfield Cleanup Grant Award
    Robert Woods Johnson Foundation Culture of Health Leader - CoHort 1
    105 Howard Ave
    Howardville, Mo. 63869
    573-233-0926 - cell
    573-688-2137 - city hall - message
    573-688-5445 - fax
    newsonlydia@gmail.com

    CONFIDENTIALITY NOTICE: This communication contains information intended for the use of the individuals to whom it is addressed and may contain information that is privileged, confidential or exempt from other disclosure under applicable law. If you are not the intended recipient, you are notified that any disclosure, printing, copying, distribution or use of the contents is prohibited. If you have received this in error, please notify the sender immediately by telephone or by returning it via email and then permanently delete the communication from your system. Thank you.