in part to keep ahead of plans for the reduction of the federal real property inventory and reinvestment in existing infrastructure, in every reporting cycle since 2004 a lack of available resources is the primary challenge to increasing capacity to identify the historic properties they own. The number of agencies citing this as the reason for doing inventory has not improved over the past three years. TVA has a general policy to survey 1,000 acres each year for historic properties. Other agencies allocating for Section 110 inventories gave several reasons for doing so. GSA said,
To remain a step ahead of plans for reinvesting in buildings potentially eligible for the NRHP, GSA’s regional preservation programs budget for Section 110 determinations of eligibility and building preservation plans as part of each region’s yearly due diligence.
Operations of the National Park Service (CR-ONPS) funding source supports research, documentation, stabilization, and conservation of NPS cultural resources, and directly supports the goals of resource stewardship, relevance, and education.These funds support park planning needs relating to proposed development and allow parks to inventory and evaluate cultural resources per the requirements of Section 110 of the NHPA.They also provide for baseline research and treatment guidance that is critical to support the streamlined compliance process for deferred maintenance and infrastructure projects that impact park resources.
NASA reports that while it has made, “a general shift from reactive, Section 106-driven identification to proactive, comprehensive Section 110 identification of historic properties” and now has “comprehensive, gate-to-gate surveys of resources over 45 years of age” at several of its Centers, it also remarked that
... the current climate of federal budgetary restrictions and the move toward commercialization of space exploration means that NASA has less discretionary funding to redirect from mission-critical programs. This can result in the deferral of Section 110 identification and reliance on Section 106 identification, since the latter is required to carry out the physical improvements necessary to advance a project, which is directly attributable to the mission.
As an example, the BOP reports that due to funding restrictions, no identification studies under Section 106 have taken place in the last three years, and it has no funding to address its facilities that are 50 years of age or older. Even agencies with substantial federal historic preservation programs have seen, at best, a flat Cultural Resource Management (CRM) funding and a consequent reduction in (or inability to fill) dedicated full-time employees (FTEs) in recent years. BLM reported that it has approximately 18 CRM vacancies, critical to an agency that manages so much land. While not providing dollar figures, the Fish and Wildlife Service (FWS) noted it was able to bring on three additional CRM positions in FY 2016, but also cautioned that it needed an additional 16 FTEs to meet current requirements. A lack of staff was the major reason FWS cited for the 169 Section 106 undertakings that were not completed in FY 2016, with the proposed activities put on hold.
BLM reports Section 110 activities occur when funding is available and staff can devote their time to those investigations, and is typically focused on high use/high impact areas.
16 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018
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