To summarize the responses about impacts of the FAST Act-Property and the FPMR, it is too early to tell how compliance may yet affect the historic property holdings of federal agencies subject to their requirements. Large agencies with a solid inventory of their historic properties (like GSA or the USPS), and smaller agencies with few (NOAA, Treasury) or specialized historic properties (NASA, DHS) are in the best position to ensure that historic values are known prior to decisions about their future. Smaller agencies stated that their existing historic properties were fully utilized and they did not expect any changes in the foreseeable future. The Section 106 review process is the vehicle most agencies will use to ensure that a property’s historic significance has a place in making decisions about retention, reuse, excessing, or disposal. Highlights: ›› GSA issued templates and guidance for landholding agencies to submit data and recommendations for real property disposal, consolidation, colocation, reconfiguration or redevelopment in support of the FAST Act-Property footprint reduction and sales revenue goals. ›› Department of Labor explicitly states these laws will not affect its historic properties or affect the mission. ›› NASA submitted its recommendations for consideration by the Public Buildings Reform Board in April 2017, identifying three facilities for potential disposal. NASA expects to coordinate with GSA for compliance with Section 106, as appropriate for the transfer of property out of federal ownership. ›› During this reporting period the ACHP published Guidance on Use of Real Property Restrictions or Conditions in the Section 106 Process to Avoid Adverse Effects (http://www.achp. gov/preservationconditions.html). This guidance, with origins in the congressionally mandated ACHP report Preserving Historic Post Offices: A Report to Congress [http://www. achp.gov/historicpostoffices.pdf ] is designed to assist federal agencies that are considering placing a covenant or Preservation Condition on properties they propose to transfer out of federal ownership. The use of a Preservation Condition to preserve historically significant characteristics of a property can lead to a finding of no adverse effect in the Section 106 review of the transfer. This guidance also educates preservation stakeholders on Preservation Conditions—what they are, who develops them, and their enforceability. The ACHP strongly supports GSA’s statement in its Section 3 report that historic building viability is best accomplished through: • reinvesting in them to continue to meet federal workplace needs; • reprogramming them to serve new uses as necessary; • outleasing vacant or underutilized historic properties to non-federal tenants when there is no immediate federal need; • leasing historic buildings from non-federal building owners, when no federal space is available; • acquiring historic properties to meet federal needs, when acquisition is cost effective and prudent; • and creating disposal strategies to promote preservation-appropriate reuse of historic properties.
54 | IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018
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