National Trust Submits Preservation Policy Priorities to Biden Administration Transition Team

January 27, 2021

In December, the National Trust met with and submitted policy priorities to the Biden-Harris transition team for the first 100 days of the new administration. Among the priorities cited were addressing proposed regulatory changes to the National Register of Historic Places, restoring Bears Ears and Grand Staircase-Escalante National Monuments, and imposing a moratorium on oil and gas leasing activities that threaten cultural resources on public lands, particularly in Greater Chaco Culture Landscape, and in the currently unprotected but culturally rich areas of Southeast Utah. Additionally, the National Trust highlighted the need for action to address the damaging changes made last summer to the regulations governing the National Environmental Policy Act and requested a full review of the Trump Administration’s reorganization of the Bureau of Land Management (BLM).

The National Trust also asked for the revocation of Secretarial Order No. 3389 that was issued in December to change DOI’s approach to Section 106 compliance under the National Historic Preservation Act. Among other things, the order restricts the use of off-site compensatory mitigation for projects where historic resources will be harmed or destroyed, requires National Environmental Policy Act review to be used as a substitute for Section 106 consultation, establishes unreasonable compliance timelines, and requires the BLM to institute a review of the existing programmatic agreement, policy directives, and other guidance documents for conformance with the order.

Each of these changes has raised troubling issues for the long-term protection of the nation’s cultural resources that the National Trust stands ready to help the new administration to address.

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