A Letter to the Secretary of the Interior from the Coalition for Cultural Justice

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
1849 C Street NW
Washington, DC 20240

 Dear Secretary Jewell:

 

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 United States and across the political spectrum for historic preservation as part of a program of flexible, humane heritage conservation. What’s more, there is mounting evidence from public health and other fields that heritage conservation benefits communities, neighborhoods, Indian tribes, and citizens in general – if it is responsive to public needs and values.

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,   

Daniel Bluestone, Professor of Architectural History and Director, Historic Preservation Program,
University of Virginia, Charlottesville,

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.