A Statement from The Penn Preservation Student Association (PPSA)

The Penn Preservation Student Association (PPSA), a student-led organization that represents students in the Graduate Program in Historic Preservation, would like to share a statement of solidarity against the proposed rule changes to the national register of Historic Places.

April 23, 2019
Re: Proposed Rule Changes to the National Register of Historic Places (National Park Service Regulation Identifier Number 1024-AE49)

Since 1966, the National Historic Preservation Act has supported the preservation of cultural heritage throughout the United States. One of the principal aspects of that legislation was the creation of the National Register of Historic Places, which the National Trust for Historic Preservation calls “an important repository of information about the nation’s historic places that also serves significant regulatory purposes.” Recently, the National Park Service proposed a suite of changes to the National Register regulations that would seriously undermine the federal government’s ability to preserve its irreplaceable cultural heritage.

Specifically, these proposed rule changes would allow federal agencies to effectively block nominations and eligibility determinations of properties in their ownership, which would limit the effectiveness of the Section 106 consultation process. They would also remove the 45-day window of review for National Register nominations, which would give the Keeper of the National Register of Historic Places the power to indefinitely refuse to act, thus stalling the nomination process. In addition, the changes would give landowners who own a majority of the area in a proposed historic district disproportionate power to object to a nomination.

These changes make the National Register nomination process less democratic by putting more decision-making authority in the hands of a select few. If these changes are approved, they will likely result in a decrease in properties that are listed in the National Register. This will remove protections from historic properties and impact the availability of financing for rehabilitation projects through the federal historic tax credit. These changes are, in and of themselves, deeply troubling because they reflect the current administration’s disregard for fair procedure and its ignorance of the multiple values of cultural heritage. In addition, the National Park Service’s failure to consult with federally-recognized Indian tribes, State Historic Preservation Officers, and other federal agencies illustrates that it is not motivated to craft regulations that benefit its constituents as well as its partner agencies and governments.

As current students and emerging professionals in the field of historic preservation, we stand alongside the National Association of Tribal Historic Preservation Officers, the National Conference of State Historic Preservation Officers, the National Trust for Historic Preservation, other preservation organizations, and thousands of individual advocates and professionals that recognize the harm these alterations will bring to the diverse buildings, cultural landscapes, tribal cultural practices, and heritage sites that comprise the historic built fabric and cultural core of our nation. We encourage fellow preservationists and all members of the public to submit formal comments by April 30, 2019 and tell the National Park Service that they oppose the proposed rule changes because the revisions do not have the best interests of our cultural heritage in mind.

In solidarity,
Penn Preservation Student Association (PPSA)
Graduate Program in Historic Preservation, University of Pennsylvania Stuart Weitzman School of Design

See below links for additional information from preservation organizations commenting on the proposed changes:
National Association of Tribal Historic Preservation Officers
National Council of State Historic Preservation Officers
National Trust for Historic Preservation
Preservation Action
Washington State Department of Archaeology & Historic Preservation

Further inquiries can be directed to the PPSA at penndesignppsa@design.upenn.edu.