In the face of numerous federal legislative efforts and budget plans proposing to cut or modify the Federal Rehabilitation Tax Credit Program (the “FRTC Program”), the Federal Historic Preservation Task Force (the “Task Force”), in its report released August 11, 2011, provides recommendations for strengthening the Federal Historic Preservation Program (the “FHP Program”) that houses the FRTC Program.  The report stresses the Task Force’s biggest concern:  that the FHP Programs will continue to be cut because their benefit and importance is not appreciated within the current structure.  Citing various facts that quantify the positive economic impact created by the FRTC Program and highlighting the positive effect historic preservation has on energy conservation, the Task Force builds a persuasive case in favor of making four systemic changes within the FHP Program that will, in turn, help insulate the FRTC Program from funding cuts.

The four Task Force recommendations are (1) to make historic preservation visible and accountable by realigning responsibilities for preservation and heritage partnership programs within the National Park Service (the “NPS”) under a deputy director for Historic Preservation and Heritage who reports to the Director of NPS, (2) designate a senior policy officer for historic preservation and heritage in the Department of the Interior to serve as a special advisor for heritage to the Secretary of the Interior, (3) make the Advisory Council on Historic Preservation chairman a full-time position, and (4) designate a senior staff position for historic and cultural resources on the President’s Council on Environmental Quality.   All of the Task Force’s recommendations focus on structural changes that will allow the FHP Program to gain more independence and priority under NPS’s umbrella, to gain more visibility within the Department of the Interior, to provide guidance to the President and Congress on matters relating to historic preservation, and to cooperate with and influence the President’s Council on Environmental Quality.

On August 25, 2011, in anticipation of its 100th anniversary in 2016, the NPS published A Call for Action, Preparing for a Second Century of Stewardship and Engagement (the “NPS Plan”).  In the Plan, the NPS’s main focus is to “recommit to the exemplary stewardship and public enjoyment of” the national parks.  NPS’s vision of a second-century national park service connects people to parks, advances the education mission, preserves America’s special places, and enhances professional and organizational excellence.  The first two of these four themes focus solely on the national parks, the third theme has an action item to “modernize historic preservation methods and technologies, show how historic structures can be made sustainable, and support efforts to rebuild the economic vitality of rural and urban communities by updating the Secretary of the Interior’s Standards and Guidelines for the Treatment of Historic Properties in consultation with historic preservation partners[,]” and the fourth theme addresses general internal matters.

The NPS Plan further supports the Task Force’s concerns about the current state of the FHP Program and is the most tangible proof that the recommendations in the Task Force’s report need to be implemented or the FHP Program will continue to be one of the government’s lowest priorities and will continue to be the among the first programs cut during these hard economic times.