The challenge of protecting widely dispersed historic resources. Several agencies, including Reclamation and NOAA, specifically noted that historic properties spread over vast areas of land or water presents a unique management challenge. Reclamation sums it up best: “protection of archaeological properties continues to be difficult given the large inventory of widely distributed sites, often in remote locations or with difficult access, and budget and staff limitations that by necessity focus time and funding upon Section 106 compliance.” NOAA cites the diverse and widespread positioning of its properties as a challenge for property management, which relates directly to limited staff to address historic preservation issues. NOAA’s Papah -anaumoku -akea Marine National Monument is one of the largest marine conservation areas in the world (and a World Heritage Site), and contains both terrestrial and underwater historic properties—shipwrecks, archaeological sites on both land and in the water, and places of traditional cultural importance to the Native Hawai’ian community and Pacific Islanders. FWS also is responsible for administering far flung resources: seven National Wildlife Refuges (NWR) in the Pacific Remote Islands Marine National Monument, including Baker Island NWR, Howland Island NWR, Jarvis Island NWR, Johnston Atoll NWR, Kingman Reef NWR, Palmyra Atoll NWR, and Wake Atoll NWR.
These agencies, along with BLM and TVA, note that current allocations are typically only sufficient to address problems brought to their attention.
In 2017, the ACHP issued the Program Comment for Telecommunications Infrastructure on Federal Property, developed through an interagency effort led by DHS, to expedite Section 106 compliance for the installation of broadband technology on federal lands addressing regulatory barriers and encouraging investment and training in order to provide access to broadband services for tribal, rural, and underserved communities. It is currently applicable to all DHS Components and the NPS, Forest Service (FS), Bureau of Indian Affairs (BIA), Rural Utilities Service (RUS), and BLM.
From BLM’s 2017 report: “The BLM’s national Programmatic Agreement with the ACHP and NCSHPO is a critical mechanism for achieving efficiencies in the Section 106 review process. In addition, the tools and processes developed by the Cultural Resources Management Program streamline the compliance process, providing flexibility and cost-savings for the bureau and land-users.”
The majority of negotiations for the CBP’s Northern and Southwest Border PAs focused on reducing the review of routine and repetitive activities that have been found to not adversely affect historic properties’ NRHP qualifying characteristics.
VA executed a statewide Programmatic Agreement for 10 medical centers in Florida in 2015 to increase compliance efficiency and focus preservation review on the single historic medical campus.
40 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018
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