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Tuesday, November 30, 2010

The Federal Historic Preservation Program Task Force: a Reaction

For some months, the Usual non-federal Suspects in U.S. historic preservation – Preservation Action, the National Conference of State Historic Preservation Officers, National Trust for Historic Preservation, American Cultural Resources Association, and others – have been deliberating earnestly as the “Federal Historic Preservation Program Task Force” (See Their task has been to examine the “external programs” in preservation managed by the National Park Service (NPS), assess their effectiveness, and come up with a “consensus plan for structural improvement,” which they will then seek to implement. The Task Force recently sent out a questionnaire to help inform its deliberations; like many others, I received a copy and amused myself for a quarter-hour or so completing it. If you haven’t gotten one yet, and want to, you can get it at

The Task Force’s effort is timely – or rather, past-timely. NPS has neglected, ignored, twisted, and distorted the “external programs” for decades, and current NPS management has shown no evidence that it has the faintest understanding even of what these programs are supposed to do. NPS – understandably enough – looks at the world outside the National Parks as something strange, vaguely threatening, and only marginally relevant, so it has made the external programs focus inward, on parks and park resources, effectively ignoring the broader responsibilities imposed by the National Historic Preservation Act and other legal authorities. This has been going on for so long that it has come to be seen – at least within NPS – as the right and proper norm. The Task Force can be congratulated for rejecting the status quo world view, for recognizing that NPS has mismanaged its responsibilities, and for attempting to effect improvements.

Sadly, though, to judge from its questionnaire, the Task Force is unlikely to accomplish much. I say this not because I think, as is widely assumed, that under current economic and political conditions nothing can be accomplished (though there’s a good deal to be said for that assumption), but because the Task Force itself seems to be little more creative or engaged with the outside world than is NPS.

After asking, in essence, whether respondents agree that NPS has done a rotten job, and understandably assuming agreement, the Task Force’s questionnaire asks us to rank several alternative pathways to program improvement. These include:

1. Pulling the external programs out of NPS and putting them into an independent agency, together with the Advisory Council on Historic Preservation (ACHP);
2. Pulling the external programs out and giving them to the ACHP;
3. Coagulating the external programs, with or without the ACHP, into a new agency within the Department of the Interior;
4. Doing the same thing within NPS;
5. Gussying up the leadership of the external programs and ACHP with things like Senate ratification of appointments; and
6. Doing nothing.

Having warned about NPS proclivities and promoted option 1 above back in the mid-1970s (See Anthropology in Historic Preservation;, I suppose I should be pleased to see the mainstream historic preservation community at last come around, and of the options given us by the Task Force, I certainly think option 1 is the best. Only with an entity that’s outside the ambit of a particular land manager – be it NPS or its parent Department of the Interior – would it be possible to develop a program that addresses historic preservation interests right across the federal establishment, in partnership (or not) with a full range of governmental and non-governmental interests. This was true in the 1970s, and it’s still true – perhaps more true – now.

But what the Task Force members – devoted, self-congratulatory preservationists all – can’t see is that “historic preservation” by itself doesn’t have the political firepower to establish or operate its own government agency – nor should it.

First: the vast majority of Americans do not know what historic preservation is – except that it’s something that keeps nice (or not so nice) old buildings standing and sometimes complicates land use and development. Most of our elected representatives are no better informed. You’re not going to get political support for something that elicits at best polite nods from the bulk of the population and members of Congress – unless you have a lot more money to pay the latter than historic preservation’s Usual Suspects have in their pockets.

More importantly, the deficiencies of the national historic preservation program are not wholly ascribable to NPS mismanagement, and they are not unique to historic preservation.

Some of the preservation program’s deficiencies are built into the National Historic Preservation Act itself, or at least into how the Act was interpreted and implemented in its earliest days (1968-72 or thereabouts). The Act and its early interpreters (admittedly, mostly NPS employees) focused attention on old buildings and archaeological sites, and turned program management over to professional historians, architectural historians, and archaeologists, creating a program that systematically excluded the broad array of landscapes, landforms, plants, animals, vistas, viewsheds, soundscapes and smellscapes that encode the cultural values of many ordinary citizens and communities – to say nothing of the less tangible aspects of culture like language, song, and tradition. Some of us have tried to drag the broader aspects of culture into the program through inventions like the “traditional cultural property” or the “cultural landscape,” but with very limited success; the deck was long ago stacked against us. As a result, we live with a program that seeks to preserve places valued by narrow disciplinary professionals, a program run by narrow disciplinary professionals for the benefit of narrow disciplinary professionals. And the Usual Suspects are – surprise! – themselves mainly narrow disciplinary professionals, or at least narrowly focused on old buildings and archaeology. Generating broad public support for an independent agency to service the interests of narrow disciplinary professionals is going to be a real challenge.

But preservation’s deficiencies are not unique; the same or very similar narrow-mindedness infects virtually every other aspect of government-based environmental management. Management of the natural living environment, when not driven wholly by economic interests, is done by and essentially for professional biologists, foresters, and the like; water resources are managed by hydrologists according to their own self-contained models, and professional environmental engineers are forever insisting that they and only they can speak to management of “the environment.” In the operation of programs designed and administered by practitioners of narrow professional disciplines, the interests, values, feelings of ordinary people have no place. Just as a community’s sense of place is likely to be ignored by the historic preservation system unless a pricy consultant is retained to translate it into terms that resonate with historians or architects, the feelings of ordinary citizens for plants, animals, lakes, rivers, language, dances, or traditions go unattended unless someone makes them sensible to biologists, ecologists, or hydrologists.

Here is where opportunity lies. If preservation’s Usual Suspects could make common cause with other groups interested in preserving cultural aspects of the environment, it just might be possible to build a broad enough support base to get something done.

Who are these groups? Here are a few with which I’ve interacted over the years, many of which have tried somehow to engage the national historic preservation program and gone away shaking their heads at its petty fixations:

Indian tribes and other indigenous groups that aren’t formally recognized by the federal government;

Property owners who value the traditional use of their land;

Equestrians and outdoorspeople who value wild horses and burros on the federal estate;

Urban and suburban neighborhoods and rural villages that like their own ambience but don’t happen to meet the National Register’s criteria;

Traditional fisherpeople, hunters, trappers, whalers (consider shrimpers on the Gulf coast);

Gatherers of traditional medicinal plants or plant foods;

People struggling to preserve threatened languages and art forms;

Local communities – including but not limited to low-income and minority ones – that just want some respect from the government.

The interests of some of these groups conflict with one another from time to time, or with the interests of historic preservation’s Usual Suspects, but they all share some common ground – which they also share, to some extent, with the ill-defined grumbling masses that make up movements like the Tea Party. And the ground they share – respect for the traditional and familiar – is thickly grown with the brambles of distrust toward narrow disciplinary professionals. As Frank Fischer put it in his wise but ill-timed book Citizens, Experts, and the Environment (Duke University Press 2000:30):

Although open protests have tended to occur only sporadically, polls show a steady decline in the public’s confidence in, and respect for, professions…. Rather than a group of experts dedicated to the public good, professionals are widely perceived as a group more interested in increasing their own authority, power, and wealth.

If preservation’s Usual Suspects could only turn around and look outside their circle, their zone of comfortable interaction with one another, of reliance on crutches like the National Register, they might, with luck, find the critical mass necessary to make useful changes in the way cultural resources are managed in this country. Such engagement with the larger world would require teetering away from our crutches, though – the National Register, the Secretary’s Standards, professional expertise as the necessary prerequisite to being heard. I don’t anticipate that the Usual non-governmental Suspects are any more willing to do that than NPS or the ACHP would be.

If they can’t look out beyond their self-referential, self-reverential circle, if they can’t step away from their crutches, preservation’s Usual Suspects both outside government and within have, I think, no chance of doing anything but holding on, tenuously, to a gradually (or maybe rapidly) deteriorating status quo. I don’t think they have the guts or brains to get outside their comfort zone, so I expect that the Task Force – well-justified as its findings may be – will be just another exercise in preservation’s long history of hand-wringing and viewing with alarm.


Anonymous said...

Tom, I'm surprised that your typical pragmatism gives way to suggesting that a new federal agency should be created for the NPS external programs orphan stepchildren. Is there another option (or options) not entertained by the task force (and imposed on interested stakeholders via the constrained survey monkey format)? Shouldn't we ask why these programs need to be kept together if they are moved? The crown jewel--rehab tax credit staff--should go to a "house" that best markets business investments (Commerce?). Why shouldn't it be peeled off of the rest of the pack? What other programs would pose the least conflict for the ACHP in its regulatory function and also not distract the agency? What could be spun off as a *new* independent federal agency but be small enough to be politically palatable (hint: the Keeper)?

Tom King said...

Well, that's not quite what I suggested. I said that of the options offered by the Task Force I thought the first (new agency) was the best, but went on to say I don't think it's realistic (pragmatic) to imagine such a thing unless it's part of something bigger, involving other aspects of the manageable environment. I think you raise a good point when you suggest splintering the program and putting its component parts where they can be most effectively managed -- Tax Act stuff to Commerce(?) for example. In this model, I'd merge ACHP and CEQ and elements of EPA. As for the Keeper, I'd probably leave her with NPS where she can be warm, fuzzy, and happy; just cut the link between the National Register and 106 so the real world doesn't have to dither about the damn thing any more.