FINDING:
Agencies should ensure timely involvement of and active collaboration with Indian tribes and Native Hawaiian organizations in property management activities and infrastructure planning.
Applicant-driven projects on or affecting historic properties on federal property create challenges for federal agencies and Indian tribes in Section 106 consultation because extensive planning typically occurs prior to the submission of an application and the initiation of the review process. When project siting and planning takes place in advance of the Section 106 process, neither federal agencies nor Indian tribes have many options to seek modifications to the project location or siting that may avoid impacts to historic properties. To address these challenges, it is essential that federal agencies and applicants include Indian tribes and NHOs in project planning and the information gathering that takes place in advance of submitting an application for federal approval or funding. Such coordination can help avoid impacts to places of religious and cultural significance to Indian tribes and NHOs, before the applicant decides on the project location and footprint.
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 recurring training in environmental and cultural resource/historic preservation responsibilities and tribal and NHO consultation. ›› Federal agencies should ensure Indian tribes and NHOs ascribing significance to properties on federal land or that could be affected by federal property management activities have the opportunity to inform programmatic approaches to maintenance, management, and planning activities.
IN A SPIRIT OF STEWARDSHIP: A REPORT ON FEDERAL HISTORIC PROPERTY MANAGEMENT 2021 | 67
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