Over the last few
months I’ve become involved with a group of academic and non-academic
practitioners of historic preservation, planning, sociology and other fields,
whose members are concerned about where historic preservation in the
United
States is going. Calling itself the Coalition for Cultural
Justice, on April 9 the group sent the following letter to the new Secretary of
the Interior.
The Honorable
Sally Jewell
Secretary of the
Interior
Congratulations
on your confirmation as Secretary of the Interior. We hope we can look to you for innovative and
creative leadership in the coming years.
Among the
less-known functions of your department is the leadership role Congress charged
it with providing in historic preservation. Under
the National Historic Preservation Act of 1966 (NHPA), the Secretary of the
Interior sets standards for historic preservation throughout the country,
oversees the State and Tribal Historic Preservation Officers, maintains the
National Register of Historic Places, and is a member of the Advisory Council on
Historic Preservation (ACHP), advising the president, congress and federal
agencies on ways to conserve the cultural heritage of the nation and its diverse
communities.
There is
widespread support throughout the
But in recent
decades, historic preservation has been bureaucratized to the point where it
often seems to serve the needs of government officials and consultants more than
those of citizens. Too much power has been concentrated in official bodies both
within your department and on the state and local levels. These officials tend to be preoccupied with
bureaucratic survival, leading them to serve development and real estate
interests with little accountability to ordinary citizens affected by their
decisions. Or they become rigid in their
interpretation of technical guidelines and unyielding in their exercise of
control, to the detriment of socially responsible planning and public
engagement.
Meanwhile,
preservation practice has come to be dominated by specialists trained in narrow
professional fields, especially architectural history and archaeology. As a
result, the systems and programs overseen by your department often focus on
places and things valued by specialists, rather than those held dear by the
public. This has particularly
unfortunate implications, both for environmental impact assessment (EIA)
conducted under the National Environmental Policy Act (NEPA) and related state
and local laws, and for historic preservation activities carried out under state
and local laws. With regard to impact assessment, much time and money is spent
analyzing impacts on places and things that meet professional criteria but may
be of little importance to the public, while environments of true cultural value
to citizens are ignored and destroyed.
The fact that
development project sponsors pay for and direct most EIA work biases the system
against conservation and deeply compromises the integrity of historic
preservation, environmental protection, and community planning. With regard to
local historic preservation, the deference accorded to the National Register and
the Secretary of the Interior’s standards by many local ordinances amplifies the
impact of too-narrow judgments at the top: these reverberate down the
preservation ladder, leading local commissions to be less responsive to local
needs than they should be.
The department
you now head, sadly, has failed to combat or redirect these tendencies. DOI’s legal mandate can, and we think should,
be interpreted as one of promoting broad, flexible heritage conservation with
sensitivity to all affected communities and interests. But in recent years the DOI has focused too
narrowly on technical matters like documenting and registering historic
buildings and archaeological sites, giving little consideration to heritage from
a community perspective.
Historic
preservation has become a cul-de-sac, isolated from broad streams of thought and
action in fields like environmental conservation, social work, public health,
community planning, public history, and community arts, as well as from the most
innovative thinking in academic disciplines like geography, anthropology, and
sociology. It has become a bureaucratic
exercise pursued by government officials and profit-seeking specialist
consultants, disconnected from communities and the cultural heritage they
value. This is not only wasteful of
money, historic properties, intellectual capital and other resources; it is
fundamentally unjust, depriving the nation’s communities of the ability to use
federal law to preserve what they think is important to maintaining and
revitalizing their cultural integrity..
As a group of
academic and non-academic practitioners of historic preservation and related
fields, we are deeply concerned about how historic preservation has drifted, and
urge you to take action to give its practice new life and direction. Specifically, we urge you
to:- Take a hard look at the National Register of Historic Places, which has come to be dominated by narrow quasi-academic interests and the economic priorities of developers seeking investment tax credits, often at the expense of community values. Consider what can be done to reorient the National Register to serve as a useful tool in community planning and heritage management; if it cannot be such a tool, perhaps the time has come to devise a better one.
- More generally,
re-think the role of the National Park Service (NPS) in the national historic
preservation program. Consider whether
the external preservation functions of NPS should be reorganized and re-tasked
to relate creatively and with understanding to the world outside the
parks.
·
Re-think the
emphasis NPS insists that State and Tribal Historic Preservation Officers and
Certified Local Governments give to National Register nominations and technical
oversight of compliance with regulatory requirements. Seek to encourage attention to the genuine
heritage concerns of citizens and communities.
·
Work with the
ACHP, the Council on Environmental Quality, and the Environmental Protection
Agency to rework the rules governing EIA, emphasizing true consultation with
affected communities, tribes, property owners and other citizens and greater
responsiveness to cultural heritage concerns; at the same time seek ways to
counter the natural influence of development interests on the consulting firms
they hire to conduct EIA work. Encourage
similar reforms by state governments.
·
Direct Interior
agencies like the Bureau of Land Management, the Bureau of Reclamation, and the
Fish and Wildlife Service to build model programs of community-oriented,
culturally sensitive EIA.
·
Encourage state,
tribal, and local governments participating in the national historic
preservation program to carry out projects linking the conservation of heritage
– including but going beyond historic preservation – with community planning and
social service agencies, so that heritage conservation serves as a component in
building and maintaining strong communities.
Evaluate, document, and disseminate the results.
Almost fifty
years ago, Congress enacted and President Lyndon Johnson signed the NHPA into
law, with its finding 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.” DOI, together with the federal
and state agencies assigned duties by the NHPA, have drifted very far from that
worthy, community-oriented goal.
We urge you to
conduct a full review of the national historic preservation program with the aim
of bringing it back to the intent of its founders, as that intent relates to the
imperatives of the twenty-first century.
We would be pleased to do whatever we can to assist in such an
enterprise.
I signed the letter, as did:
Ned Kaufman, PhD, Professional Consultant in Heritage Conservation,
David Rotenstein, PhD, Historian and
Historic Preservation Consultant,
Michael R. Allen,
Director, Preservation Research Office, Washington University in St. Louis ,
Michael Nixon,
Cultural Resources Lawyer and Consultant,
Peter
A. Primavera, Managing Partner, Peter Primavera Partners, President, National
Landmarks Alliance, and Managing Partner, Garden State
Legacy,
Danielle
Del Sol, Managing Editor, Preservation in Print Magazine and Adjunct Lecturer,
Tulane
University ,
and
Tufts
University graduate
students Andrea Devining, Alix Fellman, Maurice Robb, Merik Ugdul, Annie
McQuillan, Claire Nellisher, Osi Kaminer, Umayank Teotia, Shane McCabe,
Frederick Wolf, Blayne O’Brien, Laura Casas Fortuno, Francine Morales, Umi-hsi
Chao,
The letter has received no response,
and it’s not clear what the Coalition will do next, but its membership rolls are
open and I, at least, find it encouraging that people are thinking about and
discussing such matters.
3 comments:
Where do we sign up?
Where do we sign up?
The letter had to go, so it went, but I'd encourage people with similar (or different) points of view to write the Secretary about them, and please feel free to cite the Coalition's letter. As for participation in the ongoing activities of the Coalition, I guess we'd better figure out some more definite structure for the group, so we can communicate and plan such activities.
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