» The ACHP should issue policy guidance on Indigenous Knowledge to assist federal agencies in the identification and protection of Tribally significant resources under threat from climate change. » Agencies should leverage existing partnerships and seek opportunities to build capacity for the involvement of underserved communities in the identification and protection of at-risk historic properties of interest to them.
Permitting Improvement Steering Council, the ACHP helps agencies develop programmatic approaches to Section 106 review in line with the Steering Council’s recommended permitting best practices. The ACHP’s leadership will continue to be necessary for addressing climate-related infrastructure, and infrastructure development as a whole to support transparent and predictable review coordination.
RECOMMENDATIONS:
FINDING 2:
» Agencies should continue to pursue early coordination and planning for the development of program alternatives, including early consultation with NCSHPO (if applicable), SHPOs/THPOs, Tribes and NHOs, and consulting parties, preparing context studies and historic property inventories, and determining, in consultation with the ACHP, the best approach given an agency’s needs and concerns. » The ACHP should continue outreach to federal agencies, industry, state and Tribal officials, and other key stakeholders to identify and implement opportunities for improving the efficiency of Section 106 reviews and better coordinating review timing for infrastructure projects–including clean energy and climate-friendly transportation projects–on federal lands or property while promoting beneficial historic preservation outcomes. » The ACHP should update its Guidance on Agreement Documents to include stipulations specific to program programmatic agreements to assist agencies, State and Tribal Historic Preservation Offices, Tribes, and local governments and save time in drafting effective agreement documents.
Federal agencies are using program alternatives to constructively plan for property management activities and improve the efficiency of Section 106 project reviews while contributing to comprehensive historic property management strategies on federal lands. Agencies have effectively used Section 106 program alternatives to tailor Section 106 project reviews for multiple land- and property-managing agency benefits, including focusing limited resources on preservation priorities and contributing to comprehensive historic property management strategies. Program alternatives have also improved efficiency and effectiveness of project reviews for infrastructure projects affecting historic properties on federal lands. Over the past three years, the ACHP has seen an increase in the use of Section 106 program alternatives to support federal agency missions. Program alternatives continue to have particular relevance for addressing large-scale infrastructure development, which often crosses or occurs on federal lands, to support transparent and predictable review coordination. At the same time, the development of program alternatives needs to effectively engage all stakeholders, especially those Indigenous communities that have special relationships to properties of traditional religious and cultural significance on federal lands. Recently instituted program alternatives, developed in consultation with State and Tribal Historic Preservation Offices (and NCSHPO if on a nationwide basis), Tribes, and the ACHP, are already assisting federal agencies and consulting parties to modify the Section 106 review process; implement planning strategies; delegate or assign responsibilities; and in many cases, minimize time and resources spent on routine undertakings with little to no effect to historic properties. This allows more effective use of limited funds, directing them to larger preservation concerns. Several agencies have undertaken agency- or facility-wide surveys and historic context studies with program alternatives, which help agencies better understand their inventories, allocate appropriate resources, and more readily evaluate and respond to issues regarding properties in their care. Early, consistent, and effective consultation is crucial to program alternative development to determine deficiencies and explore avenues not initially considered by federal agencies. The ACHP’s existing Guidance on Agreement Documents continues to be a valuable resource and informs the ACHP’s various training courses and webinars on developing agreement documents. ACHP members also issued recommendations in September 2021 identifying actions the ACHP can take to improve the use of program comments as a tool for Section 106 review efficiency. And finally, as a member of the Federal
98
IN A SPIRIT OF STEWARDSHIP: A Report on Federal Historic Properties • 2024 | 99
Made with FlippingBook - Online Brochure Maker