Streamlined Process Available For NPS Approval Of Some Work On Historic Structures

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While not generally known within the agency, the National Park Service (NPS) has in place an agreement that provides for streamlined review of certain limited activities on historic or potentially historic structures.  The Programmatic Agreement (PA) between NPS and State Historic Preservation Officers (SHPOs) sets out a streamlined process to meet the requirements of the National Historic Preservation Act (NHPA) for certain types of low-impact or repetitive activities that likely have no impact on the historic aspects of a structure.  It also sets out the standard process that NPS should follow for all other projects that require review under the NHPA.  Use of the streamlined process could save you extensive time and cost in completing projects that qualify.

By way of background, the NHPA requires that projects which impact old structures which are either on the National Historic Register or eligible for listing on that register (generally structures that are over 50 years old) must first go through a consultation process with the appropriate SHPO before any work can be done.  This review can be extensive and time consuming.

However, if NPS determines that a project meets certain criteria, the extensive consultation process can be avoided.  The criteria include that all historic properties that may be impacted have been previously evaluated so that effects of the project on the property can be assessed.  In addition, the NPS official responsible for NHPA compliance has certified that the effects of the project will not adversely impact the historic nature of the structure.  The types of projects that may qualify for this streamlined process include maintenance and repair and rehabilitation or minor relocation of existing trails, walks, paths and sidewalks.  Also, projects to repair or remove existing roads, trails or parking areas may qualify.  Further, certain health and safety activities, including hazardous fuel reduction, as well as routine grounds maintenance may qualify.  Maintenance or replacement of non-historic utility lines and fences also may be eligible, along with erection of signs or meeting accessibility standards.

If you are proposing to undertake a project on a historic structure, check with your park to determine if your project is eligible for this streamlined process.  The policy requires each Superintendent to designate a park employee to be knowledgeable of and coordinate any such reviews pursuant to the NHPA.  So if your park does not have such a person, you may want to encourage your Superintendent to designate and train someone on the park staff to facilitate these reviews.


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