Your name will be included in Preservation Maryland’s official comment to the National Park Service. We strongly encourage you to take the next step and send your own comments, too. We have drafted an example letter that you can customize and send.
The National Register of Historic Places has helped Americans to identify, learn about and protect our shared cultural heritage for more than 50 years. This attempt to rewrite the rules would undercut the effectiveness of this important preservation tool. I oppose these rule changes, which would restrict nominations of federal properties to the National Register, negatively impact Section 106, reduce the availability of the federal Historic Tax Credit, and give large property owners the right to prevent listing of historic districts on the National Register.
The National Historic Preservation Act does not support or require these regulatory changes. Federal agencies should not be given a veto over nominating federally owned properties to the National Register. Local communities, tribes, and state historic preservation offices are often in the best position to understand the historic significance of these sites. Additionally, these changes would limit the ability of the Keeper of the National Register to make determinations of whether a federally owned historic property is eligible for listing on the National Register. The Keeper is the federal actor with the most expertise on historic significance determinations and their involvement should not be limited by other federal agencies.
The rule change would also allow large land owners within a proposed historic district to prevent National Register listing, even if a majority of the private property owners within the proposed district do not object. This is contrary to the statutory language of the National Historic Preservation Act, and inconsistent with the fundamental, democratic principle of one person, one vote.
Tribes were also left out of the process of developing this proposed rule making. Given the number and significance of tribal cultural resources that could be impacted by this rule change, especially resources on public lands, tribal consultation on this proposed rule is required.
I believe that the National Park Service should entirely reconsider this rule making. The rule as proposed in docket #NPS-2019-0001 will reduce the effectiveness of the National Register of Historic Places. The integrity of the National Register should be protected to ensure that it will continue to achieve its goal of preserving historic places for the benefit of current and future generations.