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Defense Department Compliance with NHPA: Section 202(a)(6) Evaluation
Department Compliance with the National Historic Preservation Act: Section
202(a)(6) Evaluation Report (1994)
Summary of Findings and Recommendations
Future Legacy Activities
List of Acronyms Used in this Report
Defense Department Compliance with the National Historic Preservation
Act: Section 202 (a)(6) Evaluation Report is a preliminary step in
helping the Department of Defense (DoD) marshal its current resourceshuman
and economicto better protect the multitude of historic properties
and other cultural resources under its jurisdiction. The report was prepared
by the Advisory Council on Historic Preservation's Office of Education
and Preservation Assistance, in cooperation with the Defense Cultural
Resources Council, the National Conference of State Historic Preservation
Officers, the National Park Service, and CEHP Incorporated, Washington,
DC, an environmental consulting firm.
Nineteenth-century life at a frontier military post is interpreted
at the Army's post museum, Fort Bliss, Texas
(Photo courtesy of U.S. Army)
Approach and Method
The Council study used several methods to evaluate programs and activities
at a variety of levels throughout the Defense Department and the armed
services. In general, these methods involved reviewing relevant materials,
such as regulations and guidance; examining available information about
current historic preservation and cultural resource management activities;
interviewing selected individuals at headquarters and major command units;
and surveying selected installations, major command and support groups,
and State Historic Preservation Officers (SHPOs) through questionnaires
and telephone interviews. Individual field visits and expert focus groups
yielded further information and enabled the Council to check lines of
inquiry and formulate conclusions.
The Council gave special consideration to issues surrounding the Defense
Department's ability to meet its responsibilities under the National Historic
Preservation Act of 1966 (NHPA), as amended (16 U.S.C. § 470), including
the manner in which cultural resources were identified, evaluated, administered,
maintained, protected, and used. The Council's authority for this study
derives from Section 202(a)(6) of the act, which directs the Council to
"review the policies and programs of Federal agencies and recommend
to such agencies methods to improve the effectiveness, coordination, and
consistency of those policies and programs with the policies and programs
carried out under [the act]." Levels of funding and personnel support
as well as opportunities for public access and involvement were investigated
in the context of the department's ongoing programs needs.
The Department of Defense has not fully met NHPA's policy provisions,
according to this study. Overall, its compliance record is inconsistent,
while its management of historic properties and other cultural resources
in particular is mediocre. Although some installations discharge stewardship
responsibilities admirably, the greater proportion do not. In many cases,
this problem can be attributed directly to inadequate staffing and funding.
Still, difficulties arising specifically from inadequate human and economic
resources are not the only ones impeding progress.
Other problems stem from sources as diverse as inconsistent legal compliance
and program administration, inadequate interaction with SHPOs, inadequate
institutionalization of historic preservation and other cultural resource
management activities at appropriate organizational levels, and inconsistent
interest and expertise in historic preservation policies and procedures
among military and civilian personnel. The low priority the department
typically assigns to staffing, funding, and planning for cultural resource
management activities, coupled with the limited attention it pays to active
management and stewardship of its historic properties and other cultural
resources, are also chronic impediments.
Among the many barriers to excellence, two key obstacles stand out: first,
the department's historic lack of commitment to natural and cultural resource
programs in relation to its primary mission, and second, its failure to
integrate resource management activities into its many ongoing programs
that have obvious cultural resource management components or implications.
If these and other barriers are to be resolved successfully, they must
be addressed in the context of military constraints, which include the
ongoing reductions in budgets and personnel and the changing military
Personnel questioned and interviewed for this study offered vital insight
into these problems. The department's compliance with the spirit and the
letter of historic preservation mandates could be improved immediately
with the hiring of additional personnel and the provision of increased
funding and training targeted for historic preservation activities. With
these changes, current practices affecting the identification, evaluation,
and protection of individual resources would be greatly enhanced.
Reasons for Encouragement
In spite of the department's current cultural resource management problems,
there are also many reasons for encouragement. A number of installations
carry out resource management responsibilities in specific program areas
in innovative ways and in an exemplary fashion, demonstrating that, with
adequate support and interest, effective resource management can be achieved.
Commended programs include ongoing archeological research and protection
at Edwards Air Force Base, California; Fort Bliss, Texas; Fort Hood, Texas;
White Sands Missile Range, New Mexico; and San Clemente Island (a sub-installation
of Naval Air Station North Island), California; historic structures management
at Wright-Patterson Air Force Base, Ohio; Fort Sam Houston, Texas; Rock
Island Arsenal, Illinois; and Pearl Harbor Naval Shipyard, Hawaii; and
overall cultural resource management strategies at F. E. Warren Air Force
Base, Wyoming; Vandenberg Air Force Base, California; Fort Lewis, Washington;
and Fort Sill, Oklahoma. Several programs at these and other installations
offer possible models for future cultural resource management endeavors
by the Defense Department or other Federal agencies.
"Kiskiack," a brick farmhouse dating to the 17th century,
at Yorktown Naval Weapons Station, Virginia (Photo courtesy U.S. Navy)
The Legacy Resource Management Program itself provides another
reason for encouragement about the prospects for historic preservation
and cultural resource management in the Defense Department. Though Legacy's
Cultural Resource Program Development Task Area, the department is making
concrete efforts, in partnership with the Council, the National Park Service,
and the National Conference of State Historic Preservation Officers, to
improve the coordination and overall quality of its cultural resource
management programs. Through training initiatives under Legacy, DoD is
addressing the critical issue of adequate personnel training in natural
and cultural resource management. Although these efforts are just beginning,
they show the department's growing awareness of the need to improve its
management of historic properties and other cultural resources. These
efforts should be continued and strengthened.
Summary of Findings
The Department of Defense has not fully complied with the policy provisions
of the National Historic Preservation Act. Its specific compliance record
is inconsistent, and its overall management of cultural resources is mediocre.
Some individuals and installations are doing an excellent job; other installations
and military commands are doing little. In large part this situation is
a result in inadequate staffing and funding, but there are many other
Major Findings and Areas for Future Examination
The Council study found:
- inconsistent legal compliance and program administration;
- a high percentage of installations (40 percent) that, according to
SHPOs, appear to have only fair, or in some cases, virtually nonexistent
interaction with SHPOs, despite the admission by installation personnel
that nearly 100 percent of the facilities in question recognized that
they had cultural resources to manage;
- with a few exceptions, inadequate institutionalization or support
for historic preservation and cultural resource management at the installation
level or higher;
- wide variation in the understanding of historic preservation laws
and policies and the sensitivity and interest of responsible personnel
and others who might affect cultural resources in significant ways;
- low priority assigned to staffing, funding, and planning for historic
preservation and cultural resource management;
- inadequate education and training to allow personnel to understand
historic preservation and other cultural resource management requirements;
- inadequate attention to the active management requirements and stewardship
of historic properties and other cultural resources.
According to Council survey respondents and outside observers, there
are many systemic, departmentwide, and servicewide barriers to cultural
resource program excellence. Two key problems lead directly to most other
existing difficulties: 1) lack of high-level commitment, and 2) lack of
effective program organization. Natural and cultural resource programs
have a second-class status and inadequate understanding, leadership, and
support as an integral part of the Defense mission. Existing programs
are fragmented and poorly integrated with other ongoing mission-related
programs with which they have clear connections, such as military and
command training, installation master planning, military construction,
operations and maintenance, environmental protection and cleanup, and
Several specific sytemwide constraints or problems were identified that
have or will have serious consequences for future programs. These problems
need to be addressed more fully in the near future and accommodated in
land and resource management planning. They include:
- downsizing and budgetary constraints;
- the changing geopolitical situation and military mission; and
- continuing advances in military technology.
Ford Island, site of Battleship Row and the 1941 Naval Air
Station that saw significant action during the Japanese attack, at Naval
Base Pearl Harbor, Hawaii (Council staff photo)
Personnel consistently cited improvements in accountability, understanding,
and integration within the Defense system as the keys to improving compliance
with historic preservation mandates and improving cultural resource management
and program operation. The department's Federal Preservation Officers,
members of the Defense Cultural Resources Council, placed personnel at
the top of their lists of critical needs, closely followed by funding
and training. Other issues, such as resource identification, evaluation,
protection, and long-term planning, are also extremely important, but
they depend to some extent on the other overriding concerns.
The Council's general recommendations to improve the effectiveness, consistency,
and coordination of Defense Department programs with national historic
preservation policy are consistent with other recommendations emerging
from Legacy-related studies, including the expert focus groups that met
during 1991 and 1992.
1. Exercise leadership and ensure better coordination among components
- Issue a directive from the Secretary of Defense to all Defense components,
military services, and major commands underscoring the importance of
compliance with historic preservation mandates and their relevance to
the Defense mission.
- Establish a position of departmental Federal Preservation Officer
within the Office of the Secretary of Defense to help coordinate activities,
educate civilian leadership, and assist in budget formulation.
- Notify other DoD offices and activities not currently complying with
historic preservation requirements or otherwise considering cultural
resource issues (e.g., Office of Economic Adjustment, Base Transition
Office, Defense Logistics Agency, Army's Toxic and Hazardous Materials
Agency, Navy's Sea Systems Command) of their responsibilities.
- Continue the coordinating and quality improvement work of the Legacy
Cultural Resource Program Development Task Area under the leadership
of the Federal Preservation Officer.
2. Establish realistic, stable funding levels.
- Establish and implement a policy directive applicable to all command
and support levels in the department that places strict limits on reprogramming
or diversion of funds earmarked for resource protection or environmental
- Examine and revise, as appropriate, guidance and instruction for
applying Environmental Compliance Account funding to historic preservation
and other cultural resource management requirements.
- Tie funding for historic preservation compliance and cultural resource
management more explicitly into the Environmental Compliance Auditing
- Assemble and assess scopes of work and other contract documents for
all elements of cultural resource managementinventories, evaluations,
feasibility studies, and treatment plansand develop guidance for
3. Enhance leadership awareness and support.
- Publicize and actively support more visible awards programs and other
incentives for cultural resource management excellence at all levels.
- Cooperate with other Federal and State agencies to develop and support
a monitoring system or "notice of violation" for cultural
resource management, possibly in conjunction with the Army's Environmental
Compliance Auditing System or similar programs in the other services.
This program could parallel the department's cooperative program with
the Environmental Protection Agency and related State agencies and could
have strong State Historic Preservation Officer participation on a cost-reimbursable
Officers' Quarters within the National Historic Landmark district
at the U.S. Naval Academy, Annapolis, Maryland (Council staff photo)
4. Improve personnel education and training.
- Develop leadership awareness and compliance education programs at
all levels of military trainingreserve officer training, reserves,
military schools and academies, basic training, advanced training, command
and leadership training, and installation indoctrination.
- Develop continuing education programs (retraining and executive briefing
sessions) tied to other environmental protection and resource conservation
programs. These programs should be aimed at commanders and senior staff
currently or potentially involved in the chain of command affecting
cultural resource management.
- Make retraining available in environmental protection and resource
management fields for Defense personnel affected by downsizing in other
department program areas.
- Develop and implement more historic preservation compliance and cultural
resource management training programs through the Army Corps of Engineers
consolidated training program.
- Cooperate with other agencies, such as the National Park Service
and the National Center for Preservation Technology and Education, to
offer hands-on training programs for civilian personnel involved in
cultural resource management. These programs should include interdisciplinary
training to encourage cultural and natural resource managers to become
more familiar with each other's programs and resource management needs.
- Continue and strengthen the Legacy Joint Education and Training Initiative
to promote and coordinate cultural resource management training.
5. Appropriately place and retain qualified personnel.
- Develop a pilot demonstration project to improve compliance skills,
particularly at smaller installations, through the use of a regional
compliance officer or through several "centers for excellence"
or consolidated facilities support divisions (such as those being developed
by the Air Force and the Navy).
- Adequately staff, support, and expand the Tri-Services Cultural Resources
Research Center at the Army Corps of Engineers' Construction Engineering
Research Laboratory (CERL) and the cultural resources programs at the
Corps of Engineers' Waterways Experiment Station, and develop cooperative
agreements between that facility and such agencies as the National Park
Service, the National Institute for Building Technology, and the National
Center for Preservation Technology and Education.
6. Better integrate historic preservation and cultural resource management
into planning and decisionmaking.
- Revise the Department of Defense directive and the Army, Navy, and
Air Force regulations and instructions relating to historic preservation
compliance and cultural resource management.
- Develop and implement a plan to integrate cultural resource management
and compliance into the Department of the Army's Directorate of Public
Works Program and its program for Integrated Training Area Management,
and make adjustments in other similar service programs. Ensure that
the plan provides for an environmental coordinator who has some training
in cultural resource responsibilities and practices at each installation
under these programs.
- Develop criteria, schedules, and budgeting for baseline inventories
of all cultural resources, and create action plans for followup activities
based on such priorities as base realignment and closure, accelerated
training, and environmental cleanup or reclamation.
- Develop and implement a plan for integrating cultural resources and
historic preservation issues into CERL's Land Condition Trend Analysis
- Fund a project to field test CERL's X-CRIS computerized installation
planning program at installations and bases of varying size, density
of use, and resource variation.
- Fund a project to assemble and assess scopes of work and other contract
documents for all elements of cultural resource inventories, evaluations,
feasibility studies, and treatment plans.
7. Improve relationships between cultural resource management and
environmental management and between cultural resource management and
facilities operation and maintenance.
- Review and revise existing service regulations and guidelines for
cultural resource management, natural resource management, and facility
engineering to ensure that cultural resource management plans and other
standard operating procedures adequately deal with the intrafacility
- Revise environmental auditing systems to reward programs that successfully
integrate disciplines at the operational level.
- Examine the placement of cultural resource management responsibilities
at the installation level through select performance reviews and consider
mandated reorganizations and other measures if necessary.
8. Enhance outside involvement in installation planning and resource
- Review existing guidance for public participation, including possible
security concerns about divulgence of planning and operations information,
and ensure that public involvement is adequately included in early planning
- Require each installation to have a public consultation plan as a
standard operating procedure in its historic preservation plan, cultural
resource management plan, or installation master plan.
- Make training on public consultation and dispute resolution techniques
available to responsible installation personnel.
Abandoned missile launch complex bunker at Cape Canaveral Air
Force Station, Florida
(Photo courtesy of U.S. Air Force)
9. Improve public education and outreach programs.
10. Improve museum functions and establish appropriate facilities for
collections care and management.
- Following the lead of the Department of the Navy in its Secretarial
Instruction dated August 1992, formally encourage closer cooperation
and working relationships between historic preservation and cultural
resource management programs and military history and museum programs.
- Evaluate public education and outreach in various Legacy demonstration
projects to determine the effectiveness and practicality of specific
types of programs or projects as models for broader emulation.
- Provide for a future review of the military history and museum programs
under each of the services, with an eye to encouraging closer cooperation
and coordination, and perhaps some consolidation, with historic preservation
and cultural resource management programs.
- Building on existing Corps of Engineers studies, and in cooperation
with the Base Realignment and Closure program and the department's Office
of Economic Adjustment, undertake pilot studies for the establishment
of new regional collections care centers or the adaptive use of excess
or surplus military facilities for these purposes. Consult with other
Federal agencies and organizations, including the National Archives
and Records Administration and the Smithsonian Institution, on their
interest in cooperating in the establishment and operation of such centers.
A number of questions should be addressed in more detail by the Legacy
Resource Management Program:
- How are the department's cultural resource management activities coordinated
under its various authorities and mandates? How can coordination be
- How can the department ensure consistent, adequate staffing and funding
and encourage use of available staff and funds to meet its cultural
resource management responsibilities?
- Where should decisionmaking authority be placed within the department
and the individual services to adequately address cultural concerns?
How can the sensitivity and awareness of
- Are procedures for planning and executing construction projects at
installations adequate to address cultural resource management concerns?
How can they be improved?
- Do the cultural resource management plans in place at some installations
serve as working tools for integrating cultural resource management
concerns with other planning and decisionmaking needs? How can these
plans best be developed and used?
- Where should cultural resource management expertise and support facilities
ideally be located? Should there be more triservice of interagency cooperative
ventures or public-private partnerships to meet such needs?
- How can the department establish and maintain an effective cultural
resource management training program?
This report represents the Advisory Council on Historic Preservation's
analysis of and recommendations regarding the Department of Defense's
historic preservation program and cultural resource management record
pursuant to Section 202(a)(6) of the National Historic Preservation Act.
The report's findings and recommendations are being used as one basis
for a second study, Defense and the Cultural Heritage: An Action Plan
for Stewardship, which is being coordinated by the National Conference
of State Historic Preservation Officers and the National Park Service.
As the Defense Department and the individual branches of the military
work to improve overall cultural resource management, however, the Council
will continue to participate in an advisory capacity. It is hoped that
the findings presented in this report will provide a firm foundation for
historic preservation and cultural resource management in the department
in the future.
List of Acronyms
Used in this Report
|| Construction Engineering Research Laboratory (Army
Corps of Engineers)
||Department of Defense
||National Historic Preservation Act of 1966
||State Historic Preservation Officer
April 30, 2002
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