On August 4, the National Trust submitted formal comments to the Department of the Interior on its proposed revisions to the implementing regulations of the National Environmental Policy Act (NEPA).

The letter underscored the essential role NEPA plays in safeguarding historic places by requiring federal agencies to evaluate the impacts of their actions and engage the public in decision-making.

We outline our three major concerns: Ensuring Adequate Analysis of Cumulative Impacts to Historic and Cultural Resources, Diminished Community-Driven Engagement, and compressed timelines without safeguards.

NEPA and Section 106 reviews can and should complement each other, and their effectiveness depends on coordinated implementation rather than competing processes.

When these reviews are aligned from the outset, agencies can avoid redundant efforts, reduce delays, and make more informed decisions.

Coordinated implementation allows for a fuller understanding of how proposed federal actions may impact historic properties. These processes in tandem would help to ensure that strategies are developed with meaningful input from State and Tribal Historic Preservation Offices, local communities, and other stakeholders.

The letter, which you can read in its entirety here, contains our 4 recommendations as well:

• Retain meaningful analysis of cumulative and indirect impacts on historic resources, in order to ensure compliance with the National Historic Preservation Act;
• Preserve robust opportunities for early and effective public participation;
• Ensure strong coordination between NEPA and Section 106 of the National Historic Preservation Act;
• Provide adequate time and resources for agencies to conduct thorough environmental and cultural resource reviews.

The National Trust also submitted letters to the Department of Transportation and the Army Corps of Engineers.