Home Publications Intro: Balancing Historic Preservation Needs with the Operation of Highly Technical or Scientific Facilities excerpt

Executive Summary
Report Conclusions
Recommendations
List of Acronyms Used in this Report

Context
In response to a joint request from the House Committee on Interior and Insular Affairs, Subcommittee on National Parks and Public Lands, and the House Committee on Science, Space, and Technology, the Advisory Council on Historic Preservation undertook an analysis of preservation issues concerning Federal support for highly scientific and technical facilities. The analysis considered the appropriate role of historic preservation in decisionmaking about the operation and management of these facilities.

When future generations reflect upon the most significant historic resources of the late 20th century, the sites associated with man's first ventures into space, the splitting of the atom, with the development of computers and artificial intelligence, and with the first successful products of genetic engineering, may well be the first examples that spring to mind. America's scientific and technical facilities stand as monuments to the Nation's supreme ability to invent and exploit new technology and to advance scientific and engineering knowledge. Some facilities and structures significant in the early history of science and technology are now inactive or have been deemed obsolete; they are in danger of being lost to future generations through lack of adequate maintenance or complete neglect.

This analysis responds to concerns on the part of the scientific community that effort to preserve or protect historic resources through compliance with Federal historic preservation law might impede efforts to stay at the forefront of international research and achievement. Many of the facilities and much of the equipment associated with scientific or engineering advancements remain in active use today, but need to be continuously upgraded and modified to stay at the cutting edge of technology. Managers and scientists fear that excessive delays, costs, or the modification or "veto" of plans for new technological facilities would inevitably result from compliance with the National Historic Preservation Act (NHPA). In addition, private institutions receiving Federal support through research grants have pointed out that such compliance would impose a burden on them to bear these monetary and other costs as a condition for receiving research funds.

Given the late-20th-century's pattern of rapid technological change, however, the protection of the physical environment that facilitated that change takes on increased importance. Federal agencies managing or assisting scientific research have a leadership role in the stewardship of historic properties under NHPA. They are obligated to present and future generations, whose tax dollars will continue to fund their operations, to consider the affects of their actions on the historic values embodied in select facilities.

The central issue discussed in this report is how organizations whose primary missions involve active research and highly technical operations can meet their obligations as stewards of the Nation's historic scientific resources, given their continuous need to modify or replace "historic" facilities and equipment. What is the appropriate balance between an agency's primary scientific and technical mission and historic preservation? How can this balance be achieved effectively and efficiently, and how can attendant costs be minimized?

The number of properties formally recognized as significant for historic scientific and technological achievements currently is fairly small. The vast majority of scientific research activities is unlikely to affect historic properties through destroying or altering their historic characteristics. Most Federal funding is used for purchasing equipment and computer time and paying staff salaries. A small minority of such activities, however, does have the potential to affect historic properties. Certainly long-term operation and management of active facilities can result in significant alterations. Further, the number of historically significant scientific properties is likely to increase in the near future as the era of World War II and its aftermath recede further into the past.

The findings and recommendations contained in this report are based on field visits to numerous affected facilities, as well as meetings with scientists, engineers, historians, facility managers, museum curators, and preservation professionals; solicitation of public comments; review of past Section 106 cases and existing agency programs; and review of National Park Service (NPS) research for the preparation of two relevant National Historic Landmark (NHL) theme studies.

The central theme of this analysis is the notion that a balance must be struck between the needs of active scientific and technological facilities and the need to preserve the physical evidence of America's scientific heritage. The analysis described the particular requirements of research organizations, investigating the foundations of their apprehensions about complying with Federal historic preservation law. This analysis has also discussed how the Section 106 process works to ensure consideration of historic values in Federal and federally assisted projects drawing upon past Council cases as well as discussions with past and present facility managers and research personnel. Finally, this report has explored both the criteria whereby facilities and objects are deemed "historically significant" and the problems that might arise in making such judgements.

The report has generated a number of conclusions that will be explored and justified in the following pages. Recommendations to better integrate preservation considerations into the conduct of Federal and federally assisted scientific endeavors conclude this report.

Although the current number of properties recognized as significant for historic scientific and technological achievements is fairly small, it is likely to increase as the era of World War II and its immediate aftermath continues to recede into the past.

The 1940s and the early 1950s were characterized by unprecedented scientific and technological achievement. As physical vestiges of those national achievements reach the 50-year threshold typically used to determine historic significance under NHPA, the pool of historically significant scientific and technological properties may increase dramatically. At the same time, continued advances in science and technology over the next decade and beyond into the 21st century can be expected to increase pressures on scientists, engineers, and managers to remove or alter historic facilities in order to keep those facilities up-to-date to meet changing technologies and uses.

The assumption expressed by some that the requirements of the NHPA are fine for road construction or urban redevelopment, but inappropriate for scientific research and development, must be rejected.

Scientific research and the space program are indeed important national priorities, but they are not necessarily more important than other national priorities such as rebuilding national infrastructure or providing affordable housing to Americans. Federal agencies and scientific research organizations have an obligation to address the requirements of NHPA in the course of carrying out their primary missions. In the case of Federal agencies owning historically significant properties, these agencies have an important stewardship role for our collective cultural heritage that they are obligated to recognize and address.

Despite the conclusion that scientific research and high technology operations should be considered no differently from other national priorities with regard to applicability of historic preservation law, there is validity to the notion that the scientific research process requires an unusual degree of flexibility in the planning and execution of research work.

It is difficult in many cases for scientists to state explicitly what effects proposed projects might have on historic resources. Research plans evolve and change during the research process; therefore, it may be impossible to specify precisely the consequences of their work with regard to physical effects on historic equipment or facilities.

Historic preservation concerns can and should be accommodated expeditiously in a way that focuses on the extremely small percentage of Federal or federally assisted projects that might have adverse effects on highly significant and historic facilities.

Programmatic Agreements (PAs) or other mechanisms that provide for tailoring of the "normal" Section 106 process to the special needs of active, operational facilities should be pursued with relevant agencies. To the extent that the regulations and procedures implementing NHPA and the application of historic preservation concepts can be fine tuned to meet the legitimate needs of the affected agencies, this should be done. Among other things, PAs can provide for stricter time limits on review and consultation that can meet concerns about expediting agency decisionmaking where necessary.

The scientific community in some cases has displayed unfamiliarity with the requirements of NHPA, and appears to perceive a threat of extended delays and other problems where there is little direct supporting experience.

Despite the fact that Federal agencies have been subject to historic preservation statutes for at least 24 years, relatively few cases involving effects on highly technical properties have gone through Section 106 review. Most Federal agencies and scientific research organizations involved with historic scientific and technical facilities do not fully understand the fine points of the Federal historic preservation review process as set forth under Section 106, much less appreciate how it could be integrated more effectively into their respective programs.

Some scientists and facilities managers, unless they have had direct experience with historic preservation project review in the past, continue to assume that Federal "historic preservation laws" mandate historic preservation, i.e., the unqualified retention of historically significant properties. Section 106 mandates that historic values be considered in overall planning for a project or program; any decision concerning preservation is made only after preservation values have been weighed against other values. There is no Federal law that requires retention of any historic property.

This perception was apparent in Council negotiations with the National Aeronautics and Space Administration (NASA) about its PA. It also has been a factor in discussions with the National Science Foundation (NSF) over an agreement covering its support of observatories. A fuller understanding of the Section 106 review process and its intended outcome could make for greater appreciation on the part of some Federal agencies concerning the possible historic significance of programs they have supported. It could also institutionalize consideration for historic values in the future within those agencies.

NASA holdings include research and experimental facilities like the 16-foot Transonic Wind Tunnel, built in 1939, at NASA Langley Research Center, Hampton, Virginia. (Photo courtesy of NASA)

With some notable exceptions, historic preservation is rarely seen as a mechanism for meeting other agency objectives. Too often, it tends instead to be viewed primarily as a "compliance problem."

The provisions of NHPA apply to all Federal agencies of the Executive Branch. As one piece of Federal environmental legislation, it can be compared to the National Environmental Policy Act — a Federal policy aimed at the full airing and consideration of environmental issues and, in the context of project decisions, with the result of more informed planning and decisonmaking. However, discussions with a variety of Federal managers for this study and direct experience by the Council staff suggests that many affected Federal agencies believe the goals of the Federal preservation program to be too nebulous to be incorporated into a coherent environmental program. Wetlands, for example, can be analyzed, assessed, and even replaced in some instances; water quality can be determined; threatened wildlife populations can be estimated. Effects on historic properties are not as easily measured. In addition, agencies often assert that the limited budget available for performing their primary "mission" automatically relegates historic preservation to a minor role in their overall program. NASA, with its visitor centers and aggressive public affairs program, is a notable exception.

This general Federal agency perception, however, coupled with the tendency to view historic facilities as simply the functional engineering structures that enabled significant events, tends to devalue the historic significance of a given facility. Practical advantages associated with historic site status may also be sacrificed. For example, it is possible that facilities formally recognized as "historic" may be better protected against the vagaries of agency budget cuts or outside development pressures, although there is conflicting evidence on this point.

The tendency to view the provisions of NHPA as merely on more hurdle in the race toward "environmental clearance" results in a loss of considerable public relations value. For example, the good that could be generated by a concerted effort to preserve in place and present to the public structures illustrative of the magnitude of the moon landing effort could help convey the message that the kinds of problems that NASA is currently experiencing with the Shuttle and the Hubble telescope are inevitable effects of scientific and engineering endeavors. Scientists rightly deplore the mediocre national standard of scientific education, yet they frequently overlook an obvious way to elevate it through historic preservation. History and science are not inherently incompatible. On the contrary, by preserving instructive physical evidence of the Apollo lunar program, among others, scientists and their agencies secure the means to memorialize heroic achievements long after generational memory has dimmed. Familiarity with this rich scientific legacy will undoubtedly encourage young people to seek careers in science and technology.

At the local level, facilities and equipment of recognized historic significance can help educate communities and their elected officials about unique concerns of sensitive, high-technology installations, such as the need for low levels of municipal lighting near a telescope, or for local zoning ordinances that could help restrict electromagnetic interference from solid waste disposal sites. These installations should be a source of pride, not the breeding grounds for local conflicts. The natural civic pride that accompanies important and historic research facilities is not typically exploited in an effective manner. Los Alamos laboratories and Kennedy Space Center are notable exceptions; they are the major employers in their locales.

Council regulations and the Section 106 review process are flexible enough to accommodate the legitimate needs of the scientific and engineering community and their activities at historic facilities.

Generally, grants for projects using existing physical plans without modifications do not take the form of undertakings within the meaning of Section 106 and, therefore, will be spared review. Similarly, work that only modifies existing equipment will have little if any effect; either no Section 106 review would be required or a summary finding of no effect would satisfy compliance requirements. Telescope improvements envisioned by institutions like the California Institute of Technology at Palomar Observatory or the University of Chicago at Yerkes Observatory, should not produce adverse effects. On the other hand, a plan affecting the integrity of the major instruments at either of these institutions could be a significant Section 106 issue. Material alterations to buildings housing scientific facilities, particularly if the structure's exterior or interior is well-known, would affect that facility; nevertheless, unless there were major changes to an important piece of scientific architecture such modifications would not be adverse.

The 200-inch Hale telescope at Mount Palomar Observatory, California, is owned and operated by the California Institute of Technology with assistance from the National Science Foundation. (Photo courtesy of CIT)

These conclusions incorporate both the concept of materiality, i.e., the quantity of change proposed, and the concept of quality, i.e., change of character or use, as opposed to the natural, ongoing change and improvement to and in structures or equipment as they are continually subjected to minor change while they continue to function for their original purpose.

All parties involved in determining the future of America's historic scientific equipment and facilities need to have a thorough understanding of what makes them significant and why.

A clear understanding of the significance of a facility, structure, or object is vital to the discussion of preservation options. This understanding, which should be predicated on agreement about exactly what is historic, is necessary if a consensus on how best to convey that significance to future generations of Americans is to be reached.

This degree of understanding is equally important for members of the historic preservation community, scientists, and managers. The latter can and should take a more active role inasmuch as they are often in a better position to judge the historic importance of their own facilities.

The historic preservation community needs to work with the scientific and engineering communities to gain a better understanding of how best to ensure the appreciation of the historically significant objects those facilities created.

The preservation community must gain a deeper understanding of the role of various facilities and structures, e.g., the Propulsion and Structural Test Facility at Marshall Space Flight Center, or the Wilson Observatory in California, played in the advancement of scientific research, if they are to determine how best to communicate this to the public. Given the various roles these facilities played both behind the scenes and in the public eye, how can this be presented? Should every historically significant object be preserved simply because it may be a unique or rare product of science and technology, e.g., a new space suit, or a Mercury capsule? These questions need to be addressed as part of a developing consensus.

The Mission Control Room at Johnson Space Center in Houston, Texas, is a National Historic Landmark for its role in the manned space program. It is shown here during a Space Shuttle mission prior to facility renovation in the 1990s. (Photo courtesy of NASA)

Discussions with Smithsonian Institution and other museum staff as a part of this study are instructive. These discussions indicate that scientific development of computers, cameras, and other technologically important but less prominent components of space vehicles are of greater interest to the public. However, if their impact is to be maximized, these objects must be interpreted with reference to their historic context and development and, where possible, with illustrations of how their development directly or indirectly currently affects the average person. The National Museum of American History's new permanent exhibit, "The Information Age," illustrates this principle. Under the rubric of space exploration, people want to see and touch actual objects that have been into space — be they capsules, rockets, spacesuits, or more mundane rocks from the moon's surface. People also are interested in the everyday life of astronauts, including their routine activities. An actual sleeping hammock used in the space shuttle is the kind of object that could easily be overlooked when discussing the preservation of man-in-space efforts, but it excites the interest of a child. Detailed printed information about rocket design, NASA missions, and hardware is also valuable, and at the facilities visited for the purpose of this study, it was apparent that this material was quite popular with visitors to these sites.

Decisions about projects that may affect historic properties need to be made with as complete an understanding as possible of such effects. However, considerations of preservation options should be kept distinct from the peer review process of awarding research grants and the determination of research priorities central to the scientific research process.

Scientists fear that the impact a proposed research project may have on historic properties ultimately will be considered in determining the project's scientific value. This, in turn, suggests that non-scientists could have a major impact on what kind of research is carried out, and where. There is a real concern on the part of the scientific community that nonscientific issues will either cloud the scientific worth of a proposed activity or result in changes that will make the research less effective or comprehensive.

These two issues, the scientific value of a research activity and the considerations of effect to historic properties, should be kept separate and distinct. The Section 106 process is ideally designed to reach a consensus on accommodating historic preservation concerns as an activity proceeds; it begins with a bias toward allowing the activity to go ahead. The law states that agencies must "take into account" the effects of their undertakings on historic properties, and afford the Council a reasonable opportunity to comment on those effects. It does not mandate preservation/retention but requires only that preservation values be considered in decisions that would alter or harm historic properties. This should not be construed by the historic preservation community as a license to scrutinize and rewrite research plans and decisions much less to open them to public debate.

Federal agencies engaged in scientific research should better acknowledge their responsibilities as stewards of America's scientific heritage and strengthen their tangible commitment to preserving the Nation's scientific legacy.

Inasmuch as scientists are potentially among the best judges of the historic value of their enterprises, it may be possible to instill more interest in preservation in those scientists who work in historic facilities. Indeed, future generations may be better served through encouraging scientists to take an active preservation role than by imposing additional layers of third-party control on managers of facilities. Plans, maps, illustrative models, and other by-products of historic events are usually on hand in the immediate aftermath of an activity; the key is to ensure their preservation and accessibility beyond the activity's completion. Scientists who are conscious of their unique responsibility as interpreters of the past will ensure that important remnants of past events are not lost. To the extent that this kind of conservatorship is already done for the benefit of scholars seeking to verify or understand past research, for public information, or public relations purposes, this will not impose an additional burden on agencies' or facilities' resources.

Throughout the Federal Government, the current personnel designated to serve as Federal Preservation Officers (or the equivalent) in accordance with Section 110(c) of NHPA often have insufficient expertise or training in historic preservation. Typically they perform their preservation function in a small amount of time taken from their other duties. They have inadequate staff to assist them, and limited additional resources. As indicated in previous Council reports to Congress, including the Regulations Effectiveness Report (January 1990), this should be corrected.

The intellectual resources of the scientists and managers who have recently retired or are nearing retirement in an asset that the Federal Government should not overlook.

Whether through soliciting assistance from such individuals in developing visitor centers or displays or through more formal projects supported by the Smithsonian Institution and others designed to record the oral histories of important programs like the manned space program, the relevant agencies should capitalize on the knowledge and experience of this group while these individuals are available.

Policy and legislation

• The Council strongly recommends that Congress not enact legislation providing exemptions from or waivers of the administration of the national historic preservation program for the benefit of specific Federal agencies or programs. Such statutory exemptions and waivers set a dangerous precedent because they are inconsistent with sound management of our Nation's historic resources, and they discourage agencies from negotiating with the Council for flexible, mutually acceptable programmatic agreements tailored to the agencies' needs. Because of the flexibility built into the national historic preservation program, no Federal agency, and specifically no agency concerned with operating scientific institutions and facilities, has made a persuasive case for needing a legislative exemption or waiver.

These interventions in the established and flexible historic preservation processes are inconsistent with the fundamental principle of NHPA and detrimental to the sound and effective management of the Nation's historic resources.

• Future scientific achievement as well as an adequate serving of the public interest is dependent on an understanding of, and excitement for, past scientific successes and failures. Therefore, to the extent that they do not already exist in agency programs, future authorizations for major scientific and technological programs should include public education components that focus in part on the communication of the relevant history of science.

• The Advisory Council on Historic Preservation should take the lead in developing and subscribing to a statement of policy that acknowledges the sensitive relationship between the progress of scientific research and the evolving history of science and its physical manifestations. Such a statement could take the form of a policy memorandum signed by the Chairman of the Council, NPS, the National Conference of State Historic Preservation Officers (NCSHPO), and various agency heads that could lay the groundwork for future consultation on specific cases or programs.

Public interpretation and education

• In addition to the need for personnel for purposes of compliance with Federal historic preservation law, relevant agencies engaged in funding highly scientific research should provide resources to allow their resident historians and archivists to begin cataloging, or to complete the cataloging and preservation of, various records and documentary media pertinent to their facilities, structures, projects and programs. This will ensure that the public will know where to look and who to talk to to find the information they need.

• Other than NASA, which already does quite a bit in this area, Federal agencies also need to strengthen their public outreach programs, through increased direct and indirect support to internal or associated museums.

• Federal agencies and preservationists need to assess how future preservation needs can be met more effectively through public/private sector cooperation. Private corporations engaged in research and development activities have made substantial contributions to the preservation and historical documentation of their own heritage, both through funding support and active preservation of their own historic structures and equipment. Many recent exhibits at the Smithsonian Institution and other museums devoted to scientific and technological themes are largely underwritten by corporate sponsors, and/or feature historic artifacts donated by these companies. The Aerospace Industries Association, a member organization comprised of approximately 50 corporate members and their subsidiaries, maintain a Washington executive office that could help serve as a clearinghouse for such efforts.

Administrative procedures

• Over the next two years, Federal agencies, in cooperation with the Advisory Council on Historic Preservation, should evaluate their current administrative procedures for historic preservation, paying close attention to mechanisms they currently have in place for meeting their responsibilities toward not only NHLs but also properties that are eligible for or listed in the National Register of Historic Places. The Council should recommend measures to improve the effectiveness, consistency, and coordination of those procedures with the purposes of NHPA, as prescribed by Section 202(a)(6).

• The Advisory Council on Historic Preservation, in cooperation with the Smithsonian Institution and NPS, should foster better communication between the preservation and museum community and Federal agencies with the aim of establishing a consensus concerning the kinds of facilities and objects that should be physically preserved and those that could be "preserved" through documentation.

• Scientific and technological agencies need to examine whether their institutional structure is such that a programmatic approach to compliance with NHPA is in their interest and to determine whether their preservation program should be carried out through a centralized office at headquarters or at the individual installation level.

• Federal agencies should examine their existing mechanisms for public involvement to ensure that these are adequate to sufficiently include those parties with legitimate historic preservation interests in the decisionmaking process. Once this is done, certain questions need to be addressed. These might include: "How are such properties and the scientific and technological history behind them being presented to the public?" and "Is there a national interest in such efforts, and if so, what is it?"

• Federal agencies need to determine more precisely the management status of historic properties for which they may be responsible where questions exist. For example, some agencies have overlapping interests or jurisdictions for the care of facilities. Agencies must examine existing legal responsibilities, as well as interests among the owners, managers, and users of these properties with regard to historic preservation. They must ensure that there are currently adequate incentives for preservation and/or public interpretation.

Staffing and training

• The Department of the Interior, in cooperation with the Smithsonian Institution, should provide technical assistance and advice to those scientific facilities around the Nation interested in identifying and evaluating the historic nature of their facilities. The information should include innovative ways in which agencies may be able to address preservation needs and responsibilities. State Historic Preservation Officer (SHPO) staff in affected States should also receive such technical assistance and advice to enhance their ability to make appropriate judgements.

• In key States that contain many potentially important historic resources of a scientific or technological nature, the Council, NPS, and NCSHPO should take the lead in working with affected agencies, private institutions, and SHPOs to facilitate interaction in workshops and other forums.

• The Advisory Council on Historic Preservation should designate one or more staff members to serve as contacts on scientific and technological programs and projects. These individuals should become thoroughly familiar with existing Federal programs and the types of historic facilities which may be affected by them.

• NASA, NSF, the United States Air Force (USAF), and the Department of Energy (DOE) should each acquire personnel with historic preservation experience for their Washington, DC, offices.

• NASA, DOE, and USAF should each designate an individual at the headquarters level to work full-time coordinating historic preservation programs and planning with facilities staff, public affairs offices, and external affairs for their respective agencies. This would include contractors and, where appropriate, visitor's centers and cooperating museums: Smithsonian Institution, Alabama Space and Rocket Center, Oak Ridge, Los Alamos, Cape Canaveral's Air Force Space Museum, etc.

Prehistoric cave sites in volcanic cliffs, some still used by local Pueblo religious practitioners, are protected within the boundaries of the Department of Energy's Los Alamos National Laboratory, New Mexico.
(Council staff photo)

• NSF should develop guidelines for NSF support that may affect historic preservation concerns. NSF should also work with recipient institutions to promote preservation of scientific and technological facilities and instruments, in conjunction with NSF's Science and Engineering Education Program. Finally, NSF should actively work with the Council, NPS, and SHPOs to address the variety of matters related to Section 106 on both a project and program-wide basis.

Funding

• Congress should consider a modest appropriation, supplemental to the NPS Fiscal Year 1992 budget, to record and document particularly vulnerable historic scientific and technical facilities and begin a systematic inventory of such resources in cooperation with agencies and SHPOs.

• Specific financial resources required to accomplish related goals should be determined, and discussions initiated toward their attainment. Specific attention should be given by all Federal agencies engaged in scientific research to the kinds of interpretive proposals and attendant costs presented in NPS's "Man in Space" study of alternatives.

• The preservation and scientific communities should discuss with Federal agencies the current and possible future preservation needs of scientific and technological properties, including, for example, whether program funds that have not normally been considered for historic preservation use, such as archival retention, cyclic maintenance, or public history, could be used to assist with physical preservation needs or onsite interpretation facilities. Money spent to advance historic preservation might well be paid back in numerous educational and other benefits.

• Existing policies restricting the use of maintenance funds for inactive or underutilized facilities should be reexamined.

• Affected Federal agencies should examine the historic scientific and technical properties in their care to determine funding needs for preservation, including documentation where physical preservation of the facility, structure, or equipment is not realistic.

Updated June 12, 2002

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