TEMPLATE FOR COMMENTS

Your specific expertise matters: please take the time to personalize these comments. The more information you include that is based on your own experiences working in CRM, the more impact your statement will have. Note: if you don't have time to personalize, please remove the words in bold below before submitting!

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I write to OPPOSE the proposed changes to the National Register regulations. I am a [insert professional interest in historic preservation—owner of a CRM consulting firm, professional archaeologist, historic architect, etc.] and write to express three major concerns with the proposed changes:

1) The proposed regulations would cut off the ability of SHPOs, THPOs, and local communities and organizations to nominate historic properties located on federal land. The changes would allow only the federal agency to submit nominations of federal properties to the Keeper. This federal overreach is inconsistent with Congress’s intent in the 2016 amendments to solicit more input from SHPOs on federal nominations. [Insert your own examples where properties on federal land were listed through efforts of SHPOs, tribes, local communities or orgs]. These changes would also cause delays in the Section 106 process, because a federal agency could prevent the Keeper from determining the eligibility of federal properties for the National Register. Such delays are contrary to the Administration’s and Congress’s goal of making the permitting review process more efficient.

2) The proposed regulations would allow large landowners to block a nomination of a historic property to the National Register. Currently, a majority of property owners can stop a National Register nomination; each property owner of a historic property gets one vote. The proposed regulations would empower the private owners of a majority of the land area to block a nomination—a change not supported by Congressional authority and clearly designed to give power to large developers to block historic property listings. These proposed regulations are designed to allow mining and energy developers to block National Register listings that encompass large scale landscapes, such as those in Alaska and the western U.S. that are culturally significant to Native Americans. [Insert your own examples of listings that could have been blocked by a majority of landowners]. Giving property owners more votes based on their landholdings is un-American and contrary to the time-tested principle of “one person, one vote.”

3) Finally, I object to the process through which these changes were developed. The National Park Service did not consult with tribes, state historic preservation officers, or other federal agencies, including the Advisory Council on Historic Preservation, to develop this rule. NPS should go back to the drawing board and enlist the expertise of professionals to develop regulations that are consistent with Congress’s intent and longstanding commitment to historic preservation.

Sincerely,

YOUR NAME