Monday, July 6, 2026

Preservationists Weigh In — Cautiously — on a Simplified Path to the National Register

Based on a June 2026 survey of historic preservation professionals

A June 2026 survey of historic preservation professionals reveals broad interest in reforming the National Register of Historic Places (NRHP) nomination process, but also deep skepticism about whether a "simplified" pathway can actually solve the problems it aims to address.

The survey, titled

Debating Changes to the NRHP: A Simplified Nomination Process, drew ten responses from a mix of state and federal government staff, nonprofit preservation professionals, academics, and private consultants. While the sample is small, the respondents represent a range of institutional perspectives — from SHPOs (State Historic Preservation Offices) to national nonprofits to academia — and their answers surface a consistent, cautious theme: reform may be worth pursuing, but only if it is grounded in a much clearer definition of what "simplified" actually means.

Who Responded

Most respondents identified as practitioners or professionals in the field (70%), with smaller shares describing themselves as preservation consultants, regulatory officers or administrators, and academics. Nonprofit organizations were the most common institutional affiliation (60%), followed by state and federal government (50% each) and local government (30%). Geographically, half of respondents described their work as national in scope, with state, local, and regional practice also represented — the Mid-Atlantic and South were the most common regions cited.

Is the Current System Failing Underserved Communities?

The survey opened by probing whether communities lacking technical expertise or financial resources struggle to protect historically meaningful places, and whether underrepresented groups remain underrepresented on the National Register. Here, the responses complicated the survey's own premise. A large majority pushed back on a simple "yes," with several respondents noting that a National Register listing does not equal protection, and that technical assistance for nominations is already available from multiple sources. On the question of underrepresentation, most respondents avoided a binary answer altogether, arguing that the answer depends heavily on geography and how "underrepresented" is defined.

This pattern — resistance to yes/no framing in favor of nuanced, conditional answers — recurred throughout the survey and became one of its most notable findings in its own right.

Appetite for Change, With Reservations

Asked directly whether the NRHP is "long overdue some serious debating," opinion was split, with many respondents objecting that the question itself was too broad to answer meaningfully. However, a strong majority (70%) agreed that the preservation community should start brainstorming and testing novel ideas, even as some cautioned that many practitioners are already innovating within the current system.

When asked whether a simplified process — reduced paperwork, notice requirements, time, and cost — could help underrepresented communities get a fair hearing, the response was overwhelmingly skeptical (90% "no"). One respondent pointed out that property owners in their state already self-prepare nominations at minimal cost, and that nomination length has grown not because of bureaucratic requirements, but because owners themselves want fuller histories documented.

Who Should Be Eligible, and What Should Disqualify a Property?

Respondents were more receptive to specific eligibility criteria than to the concept in the abstract. Indigenous tribes or tribal organizations were the most frequently cited group that should have access to a simplified pathway (50%), followed by neighborhood associations, sole property owners with income limitations, and 501(c)(3) organizations (30% each). Several respondents rejected the framing of "eligibility" altogether, arguing instead that the existing National Register program already accommodates many of these needs.

On disqualifying factors, no single issue dominated. Complex property boundaries, subsurface archaeological concerns, and extensive physical integrity issues were each flagged by 30% of respondents, but 40% said none of the listed factors should disqualify a property — suggesting reluctance to build new exclusionary criteria into a reform meant to be more inclusive.

Half of respondents supported automatically qualifying properties already listed on a State Register, though several cautioned that state registers vary too widely in rigor to generalize.

Race, Identity, and Eligibility Categories

When asked which historically underrepresented or vulnerable groups should be eligible to submit nominations under a simplified process, Black and African American communities and Indigenous, Tribal, and Native communities each drew support from 60% of respondents, with Hispanic/Latino/Chicano communities, LGBTQ+ communities, individuals with disabilities, and Asian American and Pacific Islander communities each cited by half. Notably, a handful of respondents rejected the entire premise of group-based eligibility, with one warning that using such categories risks "othering" the very communities the reform intends to help.

Technical Standards: Age, Integrity, and Significance

Familiarity with the National Park Service's existing technical concepts of "age and integrity" and "significance" was low among respondents — only 20% reported familiarity with either. Yet among the smaller subset who answered whether these concepts should remain applicable under a simplified process, the response was strongly negative: roughly 87% said no in both cases. The two write-in responses that elaborated on this point converged on the idea that historic and cultural significance should remain the central test, but that the criteria need more flexibility — with one respondent cautioning against a standard so loose that "everything is significant" and therefore nothing is.

A narrow majority (60%) supported reducing or simplifying the evidentiary burden for simplified applications. Among the smaller group who specified how, the most popular options (each cited by 100% and 75% of that subgroup, respectively) were streamlined preliminary reviews, pre-established historic contexts, standardized integrity thresholds, oral testimony via sworn statement, and delegated sign-offs. Only one respondent supported using AI to help analyze application data.

Costs, Funding, and Process Mechanics

Opinion was divided on whether the federal government should cover the cost of additional research required under a simplified process: half said "partially," with smaller shares saying "yes" or "no" outright. Respondents were similarly split on whether applicants should have to disclose funding sources or face restrictions on funding, with pluralities leaning against new disclosure or funding restrictions.

Most respondents (80%) did not think simplified applications should be reviewed on a different timeframe than standard nominations, though two who did suggest a workable range said two to six months would be reasonable. Similarly, a majority did not support creating an alternative to NPS Form 10-900, the standard nomination form — though many said they lacked enough information about the form's actual requirements to judge.

Public Participation and Next Steps

Sixty percent of respondents believed a simplified process could encourage greater public participation in preservation, though several qualified their answers by noting how vague the underlying proposal still is. Overwhelmingly — 90% of respondents — agreed that the concept needs broader discussion within the preservation community before any formal proposal reaches the Secretary of the Interior. Suggested venues for that discussion included the National Alliance of Preservation Commissions (NAPC) forum, the National Trust for Historic Preservation's annual conference, meetings of the National Conference of State Historic Preservation Officers (NCSHPO) and the National Association of Tribal Historic Preservation Officers (NATHPO), and outreach to identity-based preservation groups. One respondent urged organizers to look beyond preservation-specific circles entirely, to fields like landscape and cemetery conservation and community development, noting: "Part of the problem today is we only talk among ourselves."

Survey Design: A Recurring Complaint

A significant thread running through the open-ended responses was frustration with the survey's own framing. Several respondents noted that many questions hinged on an undefined term — "the simplified nomination process" — making it difficult to answer meaningfully. As one respondent put it, forcing complex, conditional issues into yes/no answers "introduces preferences and prejudices that cloud understanding." Despite this, 70% of respondents felt they were able to express their feedback adequately, and half felt they understood the issues and proposals well, at least in part.

Asked how often they'd want to participate in a survey like this going forward, 60% said "never," with the remainder split between "very often," "occasionally," and "not very often" — a result that likely reflects survey fatigue as much as disengagement from the underlying issue.

Closing Thoughts from Respondents

The survey's final open-ended question drew four substantive responses that, taken together, capture the field's overall posture toward reform:

        One respondent argued that a listing carries real legal and environmental weight, so any simplified nomination would still need to meet the bar for NRHP criteria — and suggested that funding context statements for underrepresented groups may be a more effective use of resources than simplifying the form itself.

        Another raised concern about creating a "two-tiered system when the problem is the system itself," proposing instead that reform efforts focus on improving the existing multiple-property documentation framework and the determination-of-eligibility process, alongside a serious conversation about what "integrity" means as a preservation standard.

        A third respondent was emphatic that any simplification "cannot be political or financial," nor "electronic or AI-related," and argued that meaningful reform depends on greater communication with local communities — a lesson they felt the preservation field should have already learned from the COVID-19 pandemic.

        A fourth respondent, planning to retire this year, simply expressed interest in following the conversation further.

Takeaways

Across nearly every question, this small but experienced group of preservation professionals showed real appetite for examining how the NRHP nomination process could better serve underrepresented communities and reduce unnecessary friction. But that appetite was consistently paired with wariness about vague proposals, concern about creating parallel review tracks, and a strong preference for grounding any changes in the existing determination-of-eligibility framework rather than building an entirely separate process. If there is a mandate here, it is less "simplify the paperwork" and more "clarify the proposal, then let the field weigh in."

This analysis is based on a survey conducted in June 2026 and should be read as a snapshot of engaged practitioner opinion rather than a statistically representative sample of the preservation field.

No comments:

Post a Comment