Statewide Historic Preservation Plans Basic Requirements Overview

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Statewide Historic Preservation Planning

  • Basic Requirement: Every SHPO must have an NPS-approved plan in place.
  • Statute: NHPA §101(b)(3)(C) or Title 54 - § 302303
  • Federal Regulation: 36 CFR 61.4(b)(1)

The SHPO must carry out a historic preservation planning process that includes the development and implementation of a comprehensive statewide historic preservation plan that provides guidance for effective decision making about historic property preservation throughout the State.

NPS Policy: Chapter 6, Section G (pages 6-8 thru 6-13), of the Historic Preservation Fund Grants Manual

Specific Planning Requirements

  • Develop a planning process that has broad-based public and professional involvement for the purpose of producing their State Plan [Chapter 6, G.2.b.2)]

NPS Recommends when developing the planning process each SHPO…scope out a robust public engagement strategy and seek out and engage...

  • Previously underserved communities (places and people)

  • American Indian tribes associated with resources (regardless of state residency)

  • Federal and state agencies whose programs and projects have significant impacts on historic resources

  • State and local elected officials

  • Business and real estate development communities

  • Local planners and regional planning organizations

In describing your State’s broad-based public participation process in the Plan, it would be best to include the list of the various groups (as listed above) and how you contacted each group, in what way did the State involve them (meeting vs survey), and summarize what were their responses.

NPS Recommends that prior to starting the public planning process that each SHPO…

Analyze existing resource data to identify gaps and potential needs—what resource types, historic contexts or regions and communities are missing, under-represented, or threatened? [Chapter 6, G.2.b.2 (SOI Planning Standards – data and historic context) and G.2.b.4.b]

Critically analyze how well the previous plans goals and objectives worked, i.e., what kind of progress was made to meet goals, were any objectives meet, were there successes, and what were the shortcomings of the plan.

Use this analysis in your discussions with the public and stakeholders during the planning process and help shape any survey questions. This is the foundation of the requirements that are checked for in the review: (1) covers full range of historic resources, and; (2) summary of assessment of resources…current state of knowledge.

  • Include a summary of the planning process and how the plan was developed [Chapter 6, G.2.b.2. and G.2.b.4.a.]

In the summary of the planning process and how the plan was developed:

  • tell the readers how you plan to implement the plan, explain any yearly work plan development process (1) the SHPO does or does not develop a yearly work plan, (2) when you develop this work plan, (3) how to provide input, if you allow input, (4) how the work plan fits into implementing the statewide historic preservation plan and, (5) how the SHPO implements the work plan. This would give any reader a real sense that the SHPO takes the plan seriously. One SHPO stated in their plan that their plan’s goals and objectives will be incorporated into staff’s performance plans.
  • This is a good place to explain how NPS requires the SHPOs to track the spending of HPF monies by tagging goals and/or objectives
  • Clearly define the plan’s cycle (i.e., how long the plan will be in effect) [Chapter 6, G.2.b.4.e.]
    • Explain why or how the SHPO chose the plan’s cycle, if there is a reason. For example, DC is in-sync with the City’s larger planning cycle, which allows them to piggy-back onto a larger public participation process that reaches non-preservation minded citizens.
  • Provide a summary assessment of current resource condition, including important issues, threats, and opportunities that effect all resource types in the State [Chapter 6, G.2.b.4.b.]
  • Goals and objectives [Chapter 6, G.2.b.4.b.]

NPS recommends that when crafting state plan goals and objectives…

  • Goals and objectives are responsive to (1) identified resource needs [analysis of National Register and State Register listings and historic contexts], (2) feedback received from stakeholders during the public engagement process and (3) issues, threats and opportunities.
  • Objectives are realistic and feasible; don’t include actions that CANNOT be accomplished during the life of the plan. This does not mean all objectives must be ACCOMPLISHED, situations change and alter the ability to accomplish objectives.
  • Propose actions that are measurable and lead directly to the fulfillment of planning objectives.

NPS Review and Approval Process

Once the plan arrives, via email or hard copy, there is a 45-day review period.

A copy of the plan is sent to other national preservation programs for comment. This includes the National Register reviewer for your state, the Tax Incentives reviewer for your state, and your NPS HPF Grant Manager. Some state plans are provided to the American Battlefield Protection Program; mostly eastern states with significant battlefield resources.

If not approved, the planning contact in the SHPO Office will be called to discuss the comments and what needs to be done to have the plan approved. Then we will negotiate how much time is needed to address NPS concerns. An email will follow that contains NPS comments and specify what needs to be revised or added for approval and what I need to re-review for the approval.

If approved:

  • NPS will send an email, to the planning contact(s), containing NPS comments and indication that the plan will be approved.
  • An “Unofficial Approval” email will then be sent, to the planning contact(s), noting that the “Official Approval” letter will be forthcoming (and to whom the letter will be addressed) and instructions on (1) printing the plan and (2) adding the new plan’s goals and objectives to the HPF Online Tracking System’s PADB.

NPS Review Worksheet/Checklist

  • Single document [G.2.b.1]
  • Time frame (planning cycle) [G.2.b.4.d]
  • Bibliography [G.2.b.4.e]
  • Vision for the state AND direction for the SHPO office, but is not an office management plan [G.1 & G.2.b.]
  • Covers full range of historic resources (Planning Standards re: data ID and assessment) [G.2.b.3]
  • Demonstrates broad-based public and professional involvement (includes those with great potential to affect resources) [G.2.b.2)]

Plan Elements [G.2.b.4)]

  • Summary of plan development, including public participation [G.2.b.4.a]
  • Summary assessment of resources, including issues, threats & opportunities, current state of knowledge [G.2.b.4.b]
  • Goals and objectives (not office management) [G.2.b.4.c]

Please note that many of the requirements listed on the Worksheet/Checklist are covered above.

Last updated: September 28, 2021