Recommendations: ›› Federal agencies should ensure all staff are aware of, and act in accordance with, government-wide and agency policies and directives regarding tribal and NHO consultation. ›› Federal agencies should ensure all appropriate staff receives training in environmental and cultural resource/historic preservation responsibilities as well as tribal and NHO consultation. ›› The ACHP should develop guidance regarding early coordination with Indian tribes and NHOs in Section 106 and pre-application processes and incorporate training regarding tribal involvement in infrastructure projects into its new training products. ›› The ACHP should work with NPS to further train and advise federal agencies on appropriate steps to identify, manage, and protect traditional cultural places of significance to Indian tribes and NHOs, including updates to existing NRHP Bulletins and guidance. FINDING: Further development of policies and procedures to assist federal agencies in considering historic properties as part of their efforts to comply with “Reduce the Footprint” requirements would improve preservation outcomes without delaying compliance with these requirements. As discussed above, the Federal Assets Sale and Transfer Act and the Federal Property Management Reform Act present historic preservation challenges and opportunities. These two laws will have a significant impact on how the federal government will consider historic significance in its footprint reduction strategies and initiatives. While agencies generally are meeting the requirements of these acts, it is often challenging for them to factor historic preservation goals and values early in agency planning to reduce federal property holdings. Developing clearer policy and procedures on when and how to consider the historic preservation values of federal assets that may be historic would better inform decisions as to whether to dispose of such an asset and help ensure the protection of those historic properties that leave federal ownership. Recommendations: ›› The ACHP should continue to work with the FRPC, GSA, and OMB to expand and improve the ACHP’s access to data within FRPP so it can continue to assist in refining data fields that provide information about federally owned historic properties and to use these data to measure trends and make recommendations on improving the management of federally owned historic properties. ›› The ACHP should identify and work with all agencies with independent disposal authority, including GSA, to develop and publish guidance on best practices and program alternatives to help those agencies complete preservation compliance for such disposals. ›› The ACHP should expand and promote its Guidance on Use of Real Property Restrictions or Conditions in the Section 106 Process to Avoid Adverse Effects to assist federal agencies in developing more effective uses of preservation covenants to expedite the disposal of historic properties by avoiding adverse effects. ›› The ACHP should continue to work with the USPS to implement recommendations within the ACHP’s earlier report, Preserving Historic Post Offices: A Report to Congress and identify other areas where it can collaborate on improving current inventory and control mechanisms that assist USPS in managing its historic assets.
IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2018 | 59
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