Home Publications Intro: Defense Department Compliance with NHPA: Section 202(a)(6) Evaluation Report excerpt

Executive Summary
Summary of Findings and Recommendations
Future Legacy Activities
Conclusion
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 resources—human and economic—to 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 mission.

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.

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 and Recommendations

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 contributing factors.

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; and

• 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 military history.

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.

Recommendations

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 and services.

• 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 compliance.

• 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 System.

• Assemble and assess scopes of work and other contract documents for all elements of cultural resource management—inventories, evaluations, feasibility studies, and treatment plans—and develop guidance for contractors.

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 basis.

4. Improve personnel education and training.

• Develop leadership awareness and compliance education programs at all levels of military training—reserve 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 Program.

• 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 professional relationships.

• 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 use.

• 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 procedures.

• 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.

9. Improve public education and outreach programs.

• 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 improved?

• 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?

Conclusion

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

Updated April 30, 2002

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