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The National Historic Preservation Program ACHP
Policy Statements ACHP Policy Statement on
Balancing Cultural and Natural Values on Federal Lands
Policy Statement on Balancing Cultural and Natural Values on Federal Lands
STATEMENT OF POLICY
ACHP [Advisory Council on Historic Preservation] seeks to promote an
approach to resource management and conflict resolution on Federally owned
public lands that achieves balance between natural and cultural values.
ACHP affirms the importance of responsible Federal stewardship of historic
properties located within natural areas; and encourages Federal land managers
to recognize that cultural and natural values are often interrelated and
should therefore be considered in an integrated manner, to ensure that
cultural values are afforded equal consideration.
State and Tribal Historic Preservation Officers, Federal Agencies, and
others who participate in the Section 106 consultation process, Federal
Agency planning processes and National Environmental Policy Act compliance
process are encouraged to use these principles as a framework for Section
106 and Section 110 consultation.
ACHP will, and other participants in the Section 106 review process for
Federal agency resource management should, be guided by the following
principles in applying the policy set forth:
- Identify potential conflicts early.
- Where potential conflicts are deemed to exist, early attention
to such problems is essential. Full study of the potentially competing
resources through land management planning processes or other land
management initiatives can lead to improved outcomes before damage
to the resources becomes irremediable.
- Demolition by neglect should be discouraged and should occur only
as a direct result of management decisions made in the context of
long-range planning with full public involvement. Such planning
initiatives should be coordinated so that impacts to the environment
and to historic properties can be addressed comprehensively.
- Differentiate between real and perceived conflicts.
- Assumptions are often made about conflicts among competing
resource values without adequate analysis of the actual effects
of such resources on one another. Is the ecosystem or natural area
in fact threatened by the presence of historic properties?
- To confront this question in the context of Section 106 consultation,
a full understanding of the resources is needed before practical
considerations can be realistically evaluated. How are the historic
areas to be used? How will they be accessed? What infrastructure
is necessary for continued use? Within the range of feasible alternatives,
is it possible to preserve resource values intact?
- Recognize that competing values involve competing constituencies.
- Consultation with both environmental advocates and
historic preservationists should be integrated rather than divided
by resource type.
- While planning initiatives may legitimately focus on subjects
of interest only to one of these advocacy categories, scheduling
separate planning initiatives should take into consideration the
interrelatedness of natural and cultural values as represented in
a given area of consideration.
- Where values are in conflict, natural and cultural resource planning
should be undertaken in concert.
- Broaden understanding of all affected resources.
- When approaching questions of historical significance,
build upon National Register criteria as commonly applied to historic
properties by drawing upon a wide range of scholarship in the agency's
evaluative and interpretive frameworks. How do the agency's cultural
landscapes illustrate the continuum of human life? To what degree
does the potentially affected area itself embody the qualities of
a heritage resource? Would interpretation of the area's associated
cultural traditions enrich understanding of the values inherent
in the area?
- Consideration should be given to the changing demographics
of visitorship to public lands in the new millennium, and the likelihood
that new visitors will bring different interests and perspectives
to their public land visitation experience.
- Recognize that acknowledgment of barriers is a first step toward problem-solving
when cultural and natural values compete.
- A host of real-world problems often contributes to
a perception that natural and cultural values cannot be reconciled.
For instance, the presence of private in-holdings or leaseholds
within Federal land boundaries may result in high sensitivity and
strained relations between the agency and the private property owner.
Often, these retained private property rights differ substantially
from those of the average user.
- Another commonly cited barrier is that requirements
of the Wilderness Act, which are recognized to be quite prescriptive,
are used for management of many ecologically significant areas within
the Federal inventory, whether or not these lands are formally designated
as wilderness. A common belief that the legal mandates of wilderness
protection supersede those of the National Historic Preservation
Act (NHPA) is often contradicted by Federal agency management policies
that allow a more balanced approach, while still adhering to the
mandates of the Wilderness Act.
- A final barrier to full consideration of historic
preservation options is a perception that preserving the natural
environment is more cost effective than preserving historic properties.
Yet costs should be viewed in the context of a multitude of factors
and with recognition that costs may be greater if neglect has already
occurred, or if labor-intensive methods must be relied upon due
to restricted access.
- Consider full range of feasible alternatives when cultural and natural
- Section 106 review and NEPA are both intended to be
used as decision-making processes. All too often, however, managers
view these procedures as a method for seeking approval for a planning
direction rather than a mechanism for formulating one. The consultation
process breaks down quickly when decisions have been resolved in
favor of a particular course of action prior to conducting a more
- Paramount to the successful resolution of competing
interests between natural and cultural resources is the commitment
to examine alternate methods for implementing an undertaking. The
stronger the ability of a land manager to consider a full range
of alternatives to a proposed action, the greater the chances will
be of discovering a resolution that addresses both cultural and
- Use an integrated approach to Section 106 review, Section 110, NEPA,
land management planning, and other authorities (such as the Wild and
Scenic Rivers Act, Native American Graves Protection and Repatriation
Act, American Indian Religious Freedom Act, Archaeological Resources
Protection Act, Section 4(f) of the Department of Transportation Act),
as a method of reaching the broadest range of the interested public.
- Planning for a wide range of resources in consultation
with the interested public can lead to conflicts among the respective
constituencies unless all such processes are interconnected. For
instance, once a land management plan is completed, the interested
public considers the Federal government to have a "contract"
with those whose views informed it. If Section 106 issues are not
adequately addressed at this stage, not only would amendments be
called for, but any necessary departure from the plan may be perceived
as a broken promise, regardless of the merits of the decision.
- Consult with Indian Tribes and Native Hawaiian organizations on the
full range of cultural and natural values.
- Federal agencies are required to ensure adequate awareness
and consideration of the interest of Indian tribes or Native Hawaiian
organizations in Federally owned resources or areas they deem of
religious or cultural significance. In doing so, agencies must adequately
recognize tribes' status as sovereign nations.
- Many times the interests of tribes do not focus merely
on cultural resources as defined by the National Register of Historic
Places but include a broad array of issues including natural and
cultural values. In fact, the very concept of separating out cultural
concerns from natural interests when assessing the merits of a particular
action is unconscionable to many tribes and Native Hawaiians. Since
Indian tribes tend to view cultural and natural resource values
as inextricably linked, rather than in conflict, land managers should
pay particular attention to their views when considering these issues.
- Consider historic values when planning for the unexpected.
- Natural disasters should be planned for to ensure
that damage to both cultural and natural resources is minimized
when disaster strikes.
- Advance preparation for unanticipated effects to known
historic properties and discoveries of previously unknown historic
properties during the course of implementing project or routine
management activities allows for timely consideration of any such
effects. When considered in the course of routine land management
planning, future emergency actions will not only be consistent with
principles of sound management but will also reflect the outcome
of consultation with the interested public.
- Because actions taken to respond to disasters or emergencies
can be as destructive as the disaster itself, planning for such
situations can mitigate damage and thereby achieve outcomes that
reinforce an agency's commitment to balanced stewardship at a time
when values inherent in the land are most threatened.
December 20, 2002
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