Detailed Information on the
National Park Service - National Historic Preservation Assessment

Use more performance data in budget requests.

Examine ways to measure and improve program cost-effectiveness.

Continue to work with SHPOs to collect and report performance information.

Determine a process and schedule for an independent evaluation of the program overall.

Assess the National Academy of Public Administration's (NAPA's) December 2007 report on its evaluation of the national historic preservation programs, the report's conclusion, and its recommendations. The report concluded that "while the program's basic structure is sound, it continues to face a number of notable challenges" that require "a stronger Federal leadership role, greater resources, and enhanced management to build on the existing, successful framework..."

Measure: Number of historic properties newly designated as National Historic Landmarks.

Explanation:2,227 NHLs in FY 1999.

Measure: Percent of designated National Historic Landmarks in good condition.

Explanation:Overall number of NHLs expected to increase slightly each year with new designations.

Measure: Number of significant historic and archeological properties that are listed in the National Register of Historic Places.

Explanation:70,019 listings in FY 1999.

Measure: Percent of historic properties found eligible for the National Register that are protected by federal historic preservation programs.

Explanation:Targets based on FY02 baseline of 3.0% (59,800 of 1,986,400). Percent may decline as the overall inventory of eligible properties grows faster than the number of listings and other protection.

Measure: Number of significant historic and archeological properties inventoried, evaluated, and officially designated by States, Tribes, and certified local governments.

Explanation:Includes 59 States and territories, 35 Tribal Preservation Offices, and 1,350 Certified Local Governments.

Measure: Cost of giving an historic property a new designation or other level of protection.

Explanation:

Is the program purpose clear?

Explanation: Overall purpose is to preserve historic properties nationwide. Achieving that purpose requires a complex inter-governmental partnership that recognizes and seeks to influence critical historic preservation decisions by local groups and private property owners through grants, incentives, national recognition, and other non-prescriptive means.

Evidence: The National Historic Preservation Act (NHPA) of 1966 sets out the overall purpose and intergovernmental structure. Components of the overall effort are addressed through other acts, such as the Historic Sites Act, the NPS Organic Act, the Archeological Resources Protection Act, the American Battlefields Protection Act, and various tax code provisions.

Does the program address a specific and existing problem, interest, or need?

Explanation: Problem is to serve the public interest in preserving historic structures of national significance, while respecting the dominant principle of private property rights. Continued interest in historic preservation can be seen through the growing popularity of historic sites; the annual additions to State's historic site inventories and NPS's National Register of Historic Places (National Register); the increasing number of preservation projects funded through the "Save America's Treasures" (SAT) grants and other sources; the Administration's 'Preserve America' initiative; the increase in Certified Local Governments (CLGs); and the growing private investment in tax-assisted historic rehabilitation projects.

Evidence: See the Historic Preservation Fund annual reports. First Lady Bush announced the Preserve America initiative on March 3, 2003. The National Register currently has 76,000 listings, compared to 71,000 in 1999. SAT grants elicited over 450 applications in 2003, up from 119 in 1999 when the program was established. Tribal assumption of SHPO duties on tribal land has grown from 12 initial tribes in 1996 to 37 in 2003. There are now 1,388 CLGs, up from 1,192 in 1999. Private investments in historic rehabilitation of commercial historic buildings encouraged through Federal preservation tax incentives has grown from $2.3 billion in 1999 to $3.2 billion in 2002 (over $28 billion in historic preservation activity has been stimulated through tax incentives since 1976).

Is the program designed so that it is not redundant or duplicative of any Federal, state, local or private effort?

Explanation: The program design depends on efforts from a wide range of governmental and private agencies, organizations, and individuals. These efforts are complementary, not duplicative. For example, Federal grants help support State Historic Preservation Offices (SHPOs) and Tribal Historic Preservation Offices (THPOs) to implement duties under both Federal and State laws. In effect, State agencies perform activities under a Federal statute in return for partial Federal funding. CLGs contribute by managing design and land use in a manner not appropriate for Federal or State governments.

Evidence: There are no duplicative programs. However, one indication of complementary efforts is the amount of non-federal funds leveraged by the program in FY 2001: $34m in HPF grants leveraged at least a matching amount of State funds; SAT grants leveraged at least $30 million; the rehabilitation tax credits stimulated $2.7 billion in private investment in historic preservation projects. Another example of complementary efforts is the coordination between SAT grants, tax credits, and listings on state and national inventories.

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The program design takes advantage of the various capabilities of the respective governmental and non-governmental partners. NPS carries out (or provides grants to SHPOs and THPOs to carry out) such governmental functions as promulgating regulations and standards, maintaining site inventories, approving National Register and National Historic Landmark (NHL) entries, and approving projects for compliance with Federal law. NPS also manages SAT grants. CLGs carry out zoning and project-specific reviews.

Evidence: The allocation of duties between Federal, State, Tribal, and local governments seems to be efficient, although there has been no cost-effectiveness study to confirm this. For example, SAT grants are targeted to avoid projects for which tax incentives or compliance regulations are the proper tool. SAT grants are competitively awarded to fill in gaps in historic preservation that are not adequately covered by Federal, State, or local programs. There are still opportunities to improve coordination between the current combination of mechanisms that make up this program.

Is the program effectively targeted, so program resources reach intended beneficiaries and/or otherwise address the program's purpose directly?

Explanation: Funds are effectively targeted to support SHPOs and THPOs in implementing Federal statues. NPS could promote effectiveness by providing incentives for SHPOs that perform well. Half of SAT grants are chosen through a rigorous competitive process, but the other half are determined through congressional earmarks, which may not go to the most meritorious projects.

Evidence: Competitive process ensures that SAT, tribal, and American Battlefield Protection Program (ABPP) project grants go to the most meritorious beneficiaries. State grants are distributed through a well-established formula process. Other Federal actions, such as accepting National Register and NHL nominations or approving projects for tax credits, follow well documented standards and guidelines. (See Secretary's Standards and Guidelines.)

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The program has multiple long-term performance measures, all keyed to the outcome of more historic properties protected outside the National Park System. The measures address different types of protection in different degrees as a result of various actions by all levels of government and the private sector.

Evidence: The long-term performance measures are specifically set out in the GPRA goals that appear in the DOI and NPS strategic plans.

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: The long-term targets are all quantified. Targets are established by analyzing previous performance and funding data to determine what is achievable, assuming level funding in the future.

Evidence: See GPRA goals cited above. Even with level funding, the targets call for an ever-increasing number of historic properties to be protected through program activities.

Does the program have a limited number of specific annual performance measures that demonstrate progress toward achieving the program's long-term measures?

Explanation: The program's annual performance measures are established, quantifiable GPRA goals. They measure the various means for achieving protection of historic properties and so are directly tied to achieving long-term targets.

Evidence: See GPRA annual performance measures for cultural resources outside the National Park System.

Does the program have baselines and ambitious targets and timeframes for its annual measures?

Explanation: Baselines have been established for annual measures by using cumulative data from previous annual reports. Annual targets, like long-term targets, are established by analyzing previous performance and funding data to determine what is achievable, assuming level funding in the future.

Evidence: See cumulative data calculations and annual GPRA goals. Annual targets call for an ever-increasing number of historic properties to be protected through program activities.

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, etc.) commit to and work toward the annual and/or long-term goals of the program?

Explanation: All state and tribal program grant recipients must prepare, carry out, and report on scopes-of-work based on duties set out in statute. All of these scopes-of-work include quantifiable measures of activities directly tied to the program's annual and long-term goals. Recipients of preservation project grants, as well as tax credit recipients, must carry out their projects in accordance with the Secretary's Standards.

Evidence: The commitment of partners is documented in grant agreements and final reports, covenants, easements, agreements by local governments to assume CLG status, agreements by tribes to assume THPO status under Section 101(d) of the NHPA, agreements by ABPP grant recipients for permanent protection of battlefields, and plans for SAT and other project-specific grants. Historically Black Colleges and Universities have not done as well in meeting program goals, as shown by the slow obligations of grant funds.

Are independent and quality evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: There have not been regularly scheduled, objective, independent evaluations of how well the program is performing. DOI should conduct (or authorize an outside entity to conduct) an independent evaluation.

Evidence: Although there have been no independent evaluations, NPS activities are regularly subject to scrutiny from state and tribal partners, outside groups (such as the National Trust for Historic Preservation, or NTHP), and other clients.

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: Program budgeting is not clearly based on performance goals. Instead, budget requests are based more on incremental changes from previous appropriations.

Evidence: Recent NPS budget request justifications do include performance measures, but they do not indicate how funding and policy decisions affect performance or why the requested mix of performance and funding is appropriate.

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: NPS continues to work with SHPOs, THPOs, and CLGs to measure performance of day-to-day operations. NPS and DOI are looking for ways to better integrate budget and performance information, such as using the PART and other information to make FY05 budget recommendations. In response to question 2.6 of this PART, DOI should conduct (or authorize an outside entity to conduct) an independent evaluation to examine program effectiveness.

Evidence: NPS ensures that: (1) States have NPS-approved Comprehensive State Historic Plans (required by Section 101(b)(3) of the NHPA); (2) State Plans are updated with community involvement at least every 5 years; and (3) each annual grant application cross-references State Plan objectives and implements the Plan through grant-assisted activities (see Chapter 7 of the HPF Grants Manual; see Georgia State Plan for 2001-2006). The NPS strategic planning process has led to more refined performance measures each year.

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: The program annually collects from States and Tribes performance data that are directly tied to the program's annual and long-term performance measures and targets. These data become the basis for determining future targets that are ambitious, but achievable. It also collects useful information on tax credits and ABPP. Better information is needed on the performance results of SAT grants.

Evidence: See sample End-of-Year reports. See also procedures for State Program Review. NPS used to conduct quadrennial, on-site reviews to confirm the accuracy of the annual data, but this process has been suspended for lack of funding. NPS will need to either reinstate these reviews or find other ways to verify the accuracy of the data.

Are Federal managers and program partners (grantees, subgrantees, contractors, cost-sharing partners, etc.) held accountable for cost, schedule and performance results?

Explanation: NPS requires States and tribes to set their specific performance targets (e.g., number of properties inventoried) and then report each year on actual performance versus targets and explain any significant deviations. Tax credit approval, Section 106 reviews, National Register listings and other activities have specific standards and timeframes that must be met to be approved. SAT grants must meet strict standards, including matching funds. In all of these cases, past performance by grantees is taken into account when making awards.

Evidence: See sample grant agreement and end-of-year report. See implementing regulations for National Register process (36 CFR 60), Section 106 process (36 CFR 800), and Tax Credit program (36 CFR 67) for timeliness measures. See 36 CFR 61 and the Secretary's Standards for quality of preservation work to be performed.

Are all funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: NPS has a "use or lose" policy that ensures timely expenditure of grant funds for state and tribal programs. Project funding is obligated as soon as feasible following competitive selection. Operating funds for NPS program staff are one-year funds with no carry-over.

Evidence: See obligation rate data, grantee expenditure data, 'use or lose' grant condition, funds recapture data, WASO expenditure records. The program receives very few grantee audit reports under the Single Audit Act, because the dollar amounts are so small.

Does the program have procedures (e.g., competitive sourcing/cost comparisons, IT improvements, approporaite incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The program has not yet established efficiency targets for grantees, as there is no current basis for determining optimal per-unit costs for mandated NHPA activities. However, some efficiency is provided through a "delegated" decision-making process that empowers front-line managers (i.e., SHPOs and THPOs) to establish and address specific preservation priorities in a manner that is most cost-effective for them. The program is reviewing options to improve IT security and efficiency.

Evidence: See organizational structure for program implementation, with many activities delegated to SHPOs and THPOs. Review of IT operations are part of a DOI-wide effort. DOI should examine options for providing incentives for SHPOs and THPOs to increase cost effectiveness.

Does the program collaborate and coordinate effectively with related programs?

Explanation: NPS collaborates closely with SHPOs, THPOs, CLGs and other groups in implementing NHPA activities. This is essential, given the decentralized structure required under NHPA. NPS also works closely with other groups, such as the Advisory Council on Historic Preservation, in implementing the Preserve America initiative. It coordinates with NEA, NEH, and IMLS in the review of SAT grant applications. The program regularly carries out cooperative projects with the National Conference of SHPOs and the NTHP.

Evidence: NPS performance measures, plans, grant announcements, and other documents are developed jointly by NPS and its partners. NPS reports are based on data collected by States and other partners. SAT grant application instructions show the level of multi-agency coordination in reviewing and approving those grants. NPS regularly provides training for Federal Preservation Officers in other agencies.

Does the program use strong financial management practices?

Explanation: Management controls introduced in 1979 result in exceptionally high obligation and expenditure rates for HPF formula grants to States and tribes. Internal controls implemented by NPS for Historic Preservation grants minimize erroneous payments. Grantees must spend or obligate 75% of grant funds within the fiscal year of appropriation, and must spend all funds by the end of the following fiscal year. Competitively awarded project grants also have expenditure deadlines; recapture rates for unspent funds are low.

Evidence: No material weaknesses related to this program. NPS minimizes erroneous payments by requiring grantee Final Project & End-of-Year Reports to compare the NPS-approved budget with costs actually incurred. If grantee has erroneously billed, NPS requires repayment. SMARTLINK electronic payments both improve efficiency and avoid erroneous payments. Other controls include a "Use or Lose" policy (amounts over 25% of a State's grant that are carried over after the first year may be reapportioned to others) and a requirement to expend all funds by the end of the second year.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: The program has internal procedures for addressing program management deficiencies, such as when SHPOs do not obligate funds as planned or significantly fall short of annual performance targets. NPS is using SMARTLINK and other IT improvements to improve efficiency.

Evidence: See sample End-of-Year reports. See also procedures for State Program Review. To avoid backsliding on management efficiencies, NPS needs to either reinstate its on-site reviews to confirm the accuracy of annual data provided by SHPOs and THPOs, or find another way to verify the accuracy of the data.

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: The program has reporting procedures for grantees to provide precise information on expenditures, FTEs, and products for each of the NHPA activities. The program has a strong relationship with its grantees and a high level of understanding of what they do, but it no longer has a regular process for reviewing the accuracy of data provided by SHPOs and THPOs.

Evidence: See sample End-of-Year reports. See also procedures for State Program Review. To avoid backsliding on management efficiencies, NPS needs to either reinstate its on-site reviews to confirm the accuracy of annual data provided by SHPOs and THPOs, or find another way to verify the accuracy of the data.

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: The program collects meaningful annual performance data from grantees. The information is compiled, aggregated, and published in an easy-to-read annual report. Information on the performance of each grantee is maintained and available to anyone in easily accessible form, but it is not published as part of the brief annual report.

Evidence: See Annual Reports and more detailed compilations.

Has the program demonstrated adequate progress in achieving its long-term outcome performance goals?

Explanation: Long-term goals reflect an ever-increasing number of historic properties that are protected by some means. The program is on track to meet each of those goals.

Evidence: See GPRA results data.

Does the program (including program partners) achieve its annual performance goals?

Explanation: Because annual goals are based on past performance and assumptions of level funding, abnormally high past performance (leading to unreasonably high expectations), or funding reductions can on occasion cause failure to meet an annual target. However, most annual targets are achieved, and use of a 3-year average mitigates unusual swings in performance.

Evidence: See GPRA Annual Reports.

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program performance goals each year?

Explanation: Although the program lacks 'per-unit-cost" efficiency measures, it has been able increase the number of properties protected with level or slightly declining funds. Better efficiency measures would likely show that this decentralized process is relatively efficient in implementing a variety of preservation tools.

Evidence: NPS has rough estimates of the cost of giving an historic property a new designation or other level of protection. This measures is still a work in progress and needs to be used in making program decisions.

Does the performance of this program compare favorably to other programs, including government, private, etc., that have similar purpose and goals?

Explanation: There are no other programs with the purpose of promoting historic preservation of private properties. Others may preserve their own historic properties, but no one else functions as coach, cheerleader, and referee.

Evidence: For the purposes of this PART, the SHPOs and THPOs that receive grants through this program are considered part of this program. These organizations are the only ones outside of NPS that have a similar responsibility for promoting historic preservation of private properties.

Do independent and quality evaluations of this program indicate that the program is effective and achieving results?

Explanation: There have not been regularly scheduled, objective, independent evaluations of how well the program is performing. DOI should conduct (or authorize an outside entity to conduct) an independent evaluation.

Evidence: None