Urge Your Representative to Sign-on to the FY22 Historic Preservation Fund Dear Colleague Letter Today!
Congress is starting the appropriations process which will determine Fiscal Year 2022 funding levels for historic preservation. The co-chairs of the Historic Preservation Caucus, Rep. Earl Blumenauer (D-OR) and Rep. Michael Turner (R-OH), are leading the bipartisan FY22 House Historic Preservation Fund (HPF) Dear Colleague Letter in the House. The letter request $150 million in funding for the HPF, the same level Preservation Action advocated for during Advocacy Week and represents full funding for the HPF. The request includes significant increases for State and Tribal Historic Preservation Offices, and increases to critically important competitive grant programs. The letter requests:
$60 million for State Historic Preservation Offices (SHPOs)
$24 million for Tribal Historic Preservation Offices (THPOs)
$20 million for the Save America’s Treasures grant program
$10 million for competitive grants for Historically Black Colleges and Universities
$9 million for the Paul Bruhn Historic Revitalization grants
$1 million for a competitive grant program to survey and document historic resources
$19 million for African American Civil Rights Initiative Competitive Grants
$7 million for the newly established competitive grants programs to preserve the sites and stories associated with securing civil rights for All Americans.
The letter also supports funding the semiquincentennial grant program to preserve historical sites commemorating the 250th Anniversary of the United States of America.
Congress needs to hear from preservation advocates
To maximize the impact of the letter, we need as many Representatives to sign-on as possible. Urge your Representative to sign-on to the bipartisan FY22 HPF Dear Colleague Letter being circulated by Representatives Earl Blumenauer (D-OR) and Mike Turner (R-OH) today!
How to Take Action:
Preservation Action has made it easy for you take action. Use our new action campaign to easily edit and send a letter to your Representative today! If you have a personal contact in your Representative’s Washington D.C. or District/State office, contact that person directly. If they do not handle Interior Appropriations please ask that they pass the message along to the Interior Appropriations staffer. The deadline for signatures is April 28th!
You can also share our Action Alert with your networks and on social media. Also be sure to share any responses you receive with Preservation Action at mail@preservationaction.org to help inform our advocacy efforts.
Today, the National Park Service announced they would be officially withdrawing the March 2019 proposal to revise regulations governing the listing of properties in the National Register of Historic Places. The proposed rule changes would have had a devastating impact on how historic resources are nominated to the National Register and determined eligible. The announcement from the National Park Service, specifically cited the more than 3,200 comments that were received and the concerns raised by the historic preservation community throughout the review process.
While it was announced in January that the proposed rule changes would not be implemented, we are very pleased the proposed rules are bring withdrawn entirely. This is a HUGE win for preservation. Thank you to everyone who made their voices heard over the last two years. Clearly the engagement of historic preservation advocates throughout the review process had a big impact.
Update: January 19, 2021
We have been advised that the proposed harmful rule changes to the National Register of Historic Places will not be implemented, according to an administration official source! This is a HUGE win for preservation and we look forward to a formal announcement coming soon!
Thanks to the more than 3,200 people who made their voices heard, the detrimental proposed regulatory changes to the National Register hit a wall! These changes would have had a significant negative impact on our communities, including how properties were nominated and determined eligible.
Update: October 30, 2020
The National Park Service is moving closer to finalizing rule changes to the National Register of Historic Places that will have a significant impact on how properties are nominated to the National Register and determined eligible. The rulemaking is currently under it’s final review by the Office of Information & Regulatory Affairs (OIRA) at the White House’s Office of Management and Budget.
At this time interested parties can request a meeting with OIRA to discuss concerns about the National Register rulemaking during this final review stage and reference RIN 1024-AE49.
Update: May 24, 2019
The National Park Service (NPS) announced, in response to concerns raised in the public comment period, that they would conduct a government to government consultation with with Tribes regarding the proposed rule changes to the National Register of Historic Places. The National Park Service will hold two consultation meetings with tribes and is accepting additional comments from tribes through July 8th. Thanks to everyone that submitted comments and made their voice heard! Check out the Tribal Consultation Notice for more information and stay tuned for the latest.
Update: May 01, 2019
Thanks to everyone who made their voice heard and submitted comments to the proposed rule changes to the National Register of Historic Places. The preservation community has spoken loud and clear, the proposed regulatory changes will have a significant negative impact on our citizens and on our communities. More than 3,200 comments were submitted, the vast majority expressing strong concerns. Preservation Action’s official comments are available below.
Now the submitted comments will be reviewed by the National Park Service. Preservation Action will continue our advocacy efforts as the process continues. Stay tuned for more.
TAKE ACTION! Submit Comments on the Proposed Rule Changes to the National Register by April 30th
Race Street in the Over-the-Rhine neighborhood of Cincinnati, OH. The Historic Tax Credit has been instrumental in the resurgence of neighborhoods like Over-the-Rhine. The proposed rule changes to the National Register could make it more difficult for communities across the country to take advantage of the Historic Tax Credit, since HTCs require the property to be listed on the National Register.
Preservation Action Objects to Harmful Proposed Rule Changes to National Register of Historic Places
Preservation Action is highly concerned with proposed revisions to the National Register of Historic Places. The proposed rule changes would substantially impact how historic resources are nominated to the National Register of Historic Places and determined eligible. While the stated intent is to bring regulations current with recent amendments to the National Historic Preservation Act (NHPA), the proposed revisions clearly go far beyond that purpose and are inconsistent with the language in and intent of the NHPA.
7 Ways the Proposed Revisions Would Negatively Impact Your Community:
1. Federal historic properties. Federal agencies will be given total control of whether to nominate properties under their jurisdiction, meaning federally owned historic properties may no longer be added to the National Register of Historic Places.
2. Federal ownership in a historic district. A historic district nomination can be blocked if only one property in the entire district is owned by the US Government and the agency that owns the property objects to listing.
3. Property owner objections. Owners of large properties will be given an outweighed ability to block the listing of historic districts or other nominations to the National Register. Under the proposed revisions, objections to National Register listings will be based on the ownership of a majority of the land area in addition to the current counting of one private owner, one vote. There is no statutory authority to make this change and any such change would place a near impossible burden on State Historic Preservation Officers to implement.
4. Historic Tax Credit Projects. The vast majority of federal historic tax credit projects are in National Register historic districts. Changing the rules for owner objections to nominations will jeopardize the listing of new historic districts, and thus restrict the use of historic tax credits.
5. Section 106. Determinations of eligibility for listing in the National Register are the primary vehicle for considering whether a property is worthy of consideration under Section 106 of the National Historic Preservation Act. The federal agency, not the Keeper of the National Register, will have the final say on the eligibility of a property under its jurisdiction, thereby thwarting consultation on a project.
6. Appeal Process. By law, any person or local government has the right to appeal the failure of a nominating authority to nominate a property to the National Register. That right will disappear if the property is a federally owned and the agency objects.
7. Consultation with Affected Parties. The proposed revisions falsely claim there would be no impact on federally recognized Indian tribes even though the changes would have a substantial effect on the recognition and consideration of historic places they value, which is contrary to the requirement to consult with tribes. Additionally, the revisions fail to consider potential concerns of State Historic Preservation Officers or others involved in historic preservation who would be drastically impacted and forced to adhere to these new rules.
Additional Resources
Preservation Action is not alone in our concerns. Read what our partner organizations have said:
COVID-19 Relief Legislation Stalled- Keep Up Your Advocacy Efforts to Include HTC Provisions
As you have probably seen in the news, congressional leaders and the White House failed to reach an agreement on the next round of COVID-19 relief and recovery legislation before departing for the August recess. The Senate released a more narrowly focused proposal in July, which centered around liability protection, adequately funding healthcare needs, and safely reopening schools. The two sides remain far apart on top line spending numbers, but both have priorities they want accomplished and face continued political forces which should keep pressure on them to return to the negotiating table. The timeline for action remains uncertain. Congress is slated to be on recess until after the Labor Day weekend, but they could be called back sooner. Preservation Action will continue to monitor the negotiations taking place and keep you posted in the latest developments. While the talks are currently stalled, it’s critical we keep up our efforts.
Join us in continuing to urge your Senators to incorporate the HTC provisions in the next round of COVID-19 relief and recovery legislation. We’re asking Senators to include the HTC changes called for in the House passed infrastructure package, the Moving Forward Act (H.R 2). This includes enhancements from the Historic Tax Credit Growth and Opportunity Act to strengthen the Historic Tax Credit (HTC) and temporary provisions aimed specifically at addressing the challenges that rehabilitation projects are facing during the pandemic. Additionally, these changes will aid economic recovery, benefiting struggling communities across the country. Specifically, we’re urging Congress to incorporate the following HTC provisions:
A temporary increase of the Historic Tax Credit from 20% to 30% for 5 years.
Establishes a permanent 30% Historic Tax Credit for projects $2.5 million and less
Eliminates the HTC Basis Adjustment, bringing more value to HTCs
Reduces the Historic Rehab Test to 50% of a building’s basis instead of 100%
Makes the credit easier to use by non-profits
A provision for communities to rehabilitate existing public schools using the HTC
Temporary extension of period for completing rehabilitation
We need your help! Continue to reach out to your Senators and urge them to include these much-needed Historic Tax Credit provisions in the next COVID-19 relief and recovery bill.
How to Take Action:
Preservation Action has made it easy for you take action. Use our new action campaign to easily edit and send a letter to your Senator’s office today! If you have a personal contact in your Senators office, reach out to them directly. You can also share our Action Alert with your networks and on social media. Also be sure to share any responses you receive with Preservation Action at mail@preservationaction.org to help inform our advocacy efforts.
Members of Congress are currently back home during the August recess, this is a great time to invite your members to safely tour a Historic Tax Credit project in their state/district. They can see first hand the impact the HTC has on their communities, the challenges many of these rehabilitation projects are facing due to the pandemic, and how the proposed changes to the HTC will help to stimulate the local economy. We hear time and again from congressional staff about the importance of congressional site visits to show the tangible impact of programs like the Historic Tax Credit.
Thanks Your Members for Supporting the Great American Outdoors Act
The House and Senate overwhelmingly passed the Great American Outdoors Act (S. 3422, H.R 7092) with strong, bipartisan support and this week the President signed it into law. This important bill will fully fund the Land and Water Conservation Fund (LWCF) at $900 million annually and provide dedicated funding to address the deferred maintenance backlog at the National Park Service and on other public lands. Thank you for reaching out to your members of Congress in support of this important bill!
The Great American Outdoors Act not only supports continued public access and enjoyment of our nation’s public lands, but also helps support and protect cultural and historic sites across the country. The LWCF has been used to preserve battlefields like Gettysburg National Military Park and iconic sites like the Brown v. Board of Education National Historic Site. The bill also addresses the nearly $12 billion backlog at the National Park Service, an estimated 43% is attributed to historic resources. Preservation Action included this important bill in our request to Congress to support historic preservation priorities in future stimulus legislation.
Thank Your Members of Congress
Preservation Action made it easy for you to take action. Send a letter directly to your members of Congress thanking them supporting the Great American Outdoors Act today!
Historic Preservation Easements Have Been Unfairly Targeted by an Aggressive IRS Campaign. Take Action!
Hotel Trundle/Powell Furniture Store in Columbia, SC used Historic Preservation Easements. Photo: GBX Group
The Federal Historic Preservation Easement program is a tax incentive that promotes the preservation and rehabilitation of historic buildings by allowing deductions for charitable contribution of historic preservation easements. Unfortunately this important program has been been undercut by an aggressive IRS campaign aimed at ending abusive conservation easement transactions. The campaign has resulted in denying nearly all conservation and historic easement deductions and thus deterring investments in historic preservation. The impact of this action on the historic preservation community is amplified as the COVID-19 pandemic has adversely impacted many historic building owners and historic rehabilitation projects.
Take Action
Write your members of Congress and urge them to work with the IRS, Treasury, the White House Office of Management and Budget’s Office of Information and Regulatory Affairs, and other agencies across the Administration on the following initiatives:
Exempt Historic Preservation Easements from the IRS enforcement campaign.
Provide clear regulations for historic property owners seeking to utilize this important program.
These actions will help ensure that historic preservationists can continue to protect and restore iconic federally recognized historic buildings across the country, furthering Congressional intent of the Historic Preservation Easement program. They will also spur new investment into historic neighborhoods in urban areas across the country, contributing to a post-pandemic economic recovery.
Send the sample letter below to your members of Congress today!
If you have a personal contact in your Representative or Senator’s Washington D.C or District office, contact that person directly. Be sure to include Preservation Action at rnaylor@preservationaction.org on your communication.
