The letter below was submitted on October 9, 2024, to the Advisory Council on Historic Preservation. Download the letter here.

October 9, 2024

The Honorable Sara Bronin, Chair
Advisory Council on Historic Preservation
401 F Street NW, Suite 308
Washington, DC 20001

The National Trust for Historic Preservation (“National Trust”) appreciates this opportunity to engage with the proposed Program Comment on Accessible, Climate Resilient, Connected Communities (“Program Comment”). We support the goals of the Advisory Council on Historic Preservation (“ACHP” or “Council”) to address the ongoing climate and housing crises our nation faces. Through the National Trust Community Investment Corporation (“NTCIC”), Main Street America (“MSA”), the new National Trust Green Fund (“NTGF”), policy and legal advocacy, and community-driven preservation projects across the country, the National Trust champions the activation, rehabilitation, and repurposing of existing historic buildings with the aim of enabling a shared and humane future.

Because the societal challenges we face require both collective action within the national preservation network and collaboration across many different sectors, we respectfully suggest that a holistic approach would be beneficial. Such an approach would allow for the implementation of a simplified, comprehensive process that facilitates community-serving rehabilitative, retrofitting and adaptive re-use projects while also honoring the distinctive historic fabric that these communities value. Without a holistic approach, we question whether the Program Comment can achieve its maximum impact.

Such a comprehensive approach would necessarily involve a collective assessment of both Section 106 consultations and the application of the Secretary of the Interior’s Standards for Rehabilitation. Are there, for example, categories of undertakings (e.g. moving interior walls and other interior alterations) or even categories of buildings where the overall process, from start to finish, can be simplified while also enabling broad community engagement? We also suggest that, given the anticipated federal investment in the retrofitting of older buildings through the Greenhouse Gas Reduction Fund (GGRF), a streamlined process tailored for these projects would significantly accelerate climate-friendly adaptation of the built environment.

The National Trust acknowledges the efforts the Council has undertaken to highlight how the processes in place, in spite of best intentions, impede our collective response to current crises. We share the Council’s sense of urgency. We believe that all parties across federal agencies and the preservation community share ACHP’s goals. If they are to be implemented quickly, the start-to-finish processes we’re suggesting will rely on expertise that these parties possess and the leadership they can provide.

This Program Comment aims to simplify particular aspects of the complex processes through which undertakings potentially impacting historic resources are assessed. We support this aim, and evaluating the impact of these undertakings will often rely on local expertise, Tribal consultation, and broad community input (For example, who will decide which façades are primary in any given community?). We respectfully urge that these voices be incorporated into a subsequent draft of the Program Comment so that the suggested approach does not unintentionally cause avoidable harm or obstruct future collaboration.

Through our work, the National Trust family of entities (NTCIC, MSA, NTGF, and NTHP) partners with many communities and constituencies who do not speak with one voice. We are, however, united in our commitment to working directly with local communities. Many of our initiatives prioritize places that investment dollars—whether for preservation, rehabilitation, retrofitting, or adaptive reuse—don’t easily reach. As we work together to adapt and implement processes that meet the moment, protecting the agency of local communities we aim to serve will matter.

Included is a redlined version of the Program Comment prepared by our legal advocacy team along with observations from NTGF and MSA. Thank you for inviting our comments and views.

Sincerely,

Carol Quillen, President and CEO