{"id":36885,"date":"2023-06-30T18:21:12","date_gmt":"2023-06-30T17:21:12","guid":{"rendered":"https:\/\/newsblogsnew.ihbc.org.uk\/?p=36885"},"modified":"2023-06-30T18:21:12","modified_gmt":"2023-06-30T17:21:12","slug":"ihbc-practice-signpost-from-the-us-request-for-comments-on-application-and-interpretation-of-standards-for-the-treatment-of-historic-properties","status":"publish","type":"post","link":"https:\/\/newsblogs.ihbc.org.uk\/?p=36885","title":{"rendered":"IHBC Practice Signpost from the US: \u2018Request for comments on Application and Interpretation of\u2026 Standards for the Treatment of Historic Properties\u2019"},"content":{"rendered":"

\"\"Fulfilling its duty to advise the White House, Congress, and executive branch agencies pursuant to the National Historic Preservation Act, the Advisory Council on Historic Preservation invites public feedback regarding application and interpretation of the Secretary of the Interior\u2019s Standards for the Treatment of Historic Properties\u2026 and\u2026 guidelines.<\/h3>\n

<\/p>\n

\u2026 How might guidance, training, or other actions\u2026.improve the federal response\u2026<\/span><\/em><\/h2>\n

The Advisory Council on Historic Preservation writes:<\/p>\n

The Department of the Interior sets out four treatments in the Secretary\u2019s Standards:\u00a0\u00a0preservation, rehabilitation, restoration, and reconstruction.\u00a0\u00a0Each of the four Standards differs slightly in its articulation and in the expected results.<\/p>\n

The call for comments about the Secretary\u2019s Standards is further articulated below. Comments must be submitted in writing by\u00a05 p.m. on July 20, 2023, by emailing\u00a0dnull@achp.gov<\/a>. Major themes and issues that emerge from the comments received will be shared with the Department of the Interior, which is a member of the Advisory Council on Historic Preservation, and the National Park Service, which is the bureau of the Department of the Interior tasked with promulgating regulations and issuing guidance related to the Secretary\u2019s Standards.<\/p>\n

Importance of the Secretary\u2019s Standards<\/h2>\n

The Secretary of the Interior\u2019s Standards for the Treatment of Historic Properties(36 C.F.R. Part 68) provide guidance that is central to implementation of federal, state, and local historic preservation law. The application and interpretation of the Secretary\u2019s Standards and associated guidelines significantly affect public and private projects involving historic properties, influence strategies and techniques people choose to deploy, change costs associated with addressing historic property issues, and shape distributional equity. In some cases, the Secretary\u2019s Standards may affect the ability to address the pressing challenge of climate change both through and on behalf of historic properties.<\/p>\n

The Secretary\u2019s Standards are enshrined in law and policy guidance across different agencies and programs.\u00a0\u00a0For example, they are referenced in the\u00a0Advisory Council on Historic Preservation regulations\u00a0(36 CFR Part 800), which guide federal agencies in complying with the requirements of Section 106 of the National Historic Preservation Act to consider the effects of federal undertakings on historic properties. Such undertakings are considered to have an adverse effect under Section 106 if associated rehabilitation work is inconsistent with the Secretary\u2019s Standards. They are also referenced in the\u00a0National Park Service guidelines\u00a0for Section 110 of the National Historic Preservation Act, which deals with federal agency historic preservation programs. And they are referenced in the\u00a0Council on Environmental Quality regulations\u00a0(including 36 C.F.R. \u00a7 1010) regarding environmental impact statements under the National Environmental Policy Act.<\/p>\n

Of the four Standards, the\u00a0Secretary\u2019s Standards for the Rehabilitation of Historic Properties\u00a0(Standards for Rehabilitation) have been most fully incorporated into law and policy guidance. A version of the Standards for Rehabilitation (36 C.F.R. Part 67) must be met for a rehabilitation project to be certified by the National Park Service as qualifying for a federal\u00a0Historic Preservation Tax Credit,\u00a0and conformance with the Standards for Rehabilitation is often a requirement for state historic preservation tax credits. In addition, many local historic preservation commissions either use the Standards for Rehabilitation to guide implementation of local historic preservation ordinances or have tailored local standards based on them.<\/p>\n

Call for Comments<\/h2>\n

The Advisory Council on Historic Preservation wishes to obtain a snapshot of public views on the current application and interpretation of the Secretary\u2019s Standards and associated guidelines to assist us in both overseeing the Section 106 review process and in providing recommendations to the Secretary of the Interior on measures to coordinate activities of federal, state, and local agencies related to historic preservation.<\/p>\n

While comments will be accepted addressing the Secretary\u2019s Standards in any respect, the following questions are of special interest:<\/p>\n

1.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0Are you aware of any substantive or procedural issues (e.g., uncertainties, discrepancies, or conflicts) related to the application and interpretation of the Secretary’s Standards and associated guidelines in the following contexts? Are you aware of cost, equity, housing-supply, energy efficiency, renewable energy, or climate-change-related (e.g., adaptation or mitigation) concerns related to the application and interpretation of the Secretary’s Standards and associated guidelines in the following contexts?<\/p>\n