National Register of Historic Places: Selected States and Tribes Identified Challenges to Participation
Fast Facts
The National Register of Historic Places is administered by the National Park Service with cooperation from states and Tribes. The Register includes over 100,000 historically significant places.
However, some states noted that the nomination guidance was outdated and challenging for the public to understand. Some Tribes noted that the criteria for evaluating properties is difficult to apply to their sites; they also were uncertain of how to protect sensitive site locations from public disclosure.
Such challenges may lead to more time spent on nominations, or potential nominations not being submitted. Our recommendations address these issues.
Booker T. Washington High School in Georgia, a Property Listed on the National Register of Historic Places
The front of a brick school building with a stairway leading up to the entrance.
Highlights
What GAO Found
The National Register of Historic Places is the nation’s official list of historic places worthy of preservation. The National Park Service (NPS) administers the National Register in cooperation with states and Tribes. Each state has established a State Historic Preservation Officer (SHPO) whose responsibilities include identifying and nominating eligible properties to the National Register. Additionally, Tribes may elect to establish a Tribal Historic Preservation Officer (THPO).
Officials from SHPO offices GAO interviewed identified a number of challenges with the National Register process, including that some key NPS guidance documents were outdated and did not have information that would help them effectively nominate properties. Because of these challenges, some of these officials noted that developing nominations required additional time and resources. While NPS officials told GAO they intend to update some guidance documents, they have not developed a plan to do so, including a plan to identify what information SHPOs and THPOs need in updated guidance. Developing such a plan will help NPS better ensure the update includes the information that SHPOs and THPOs—their primary users—need to effectively participate in the program.
Tribes GAO spoke with also identified challenges with the National Register process. Some Tribes and tribal organizations told GAO that the National Register evaluation criteria do not always accommodate historically significant tribal properties. NPS officials told GAO they have taken actions to clarify the ways in which Tribes can apply the criteria, including revising guidance on listing traditional cultural places. However, conducting outreach to Tribes to highlight relevant guidance on applying the National Register criteria could provide better assurance that the National Register includes historic properties significant to Tribes.
Some Tribes GAO interviewed also expressed concern that nominating properties to the National Register could result in unwanted visitation or looting of sites. The location of properties on the National Register can be withheld from public disclosure in certain circumstances. While NPS has taken productive steps to communicate information about this provision, some Tribes GAO spoke with were not aware of it or continued to have concerns about sharing information about properties. Conducting outreach to Tribes on the ability to withhold this information would better ensure they are informed of this provision and may mitigate continuing concerns among Tribes about sharing information about their historic properties.
Why GAO Did This Study
The National Register is a key part of federal efforts to identify and protect America's historic and archeological resources. Over 100,000 properties are listed in the National Register, including buildings, objects, and sites. However, some stakeholder groups have raised questions about whether the National Register is representative of the nation’s full story.
GAO was asked to review how NPS administers the National Register and any challenges SHPOs and THPOs may face in the listing process. This report discusses the National Register listing process and examines challenges faced by selected SHPOs and THPOs and the public.
GAO reviewed relevant laws and regulations, analyzed NPS guidance documents, and interviewed NPS officials who administer the National Register. GAO also interviewed officials from a nonrepresentative selection of nine SHPO offices and eight federally recognized Tribes. GAO selected these SHPO offices and Tribes to reflect variation in the number of sites they had listed to the National Register from 2019 through 2024 and geographic diversity, among other factors.
Recommendations
GAO is making four recommendations, including that NPS develop a plan to update its guidance on nominating properties to the National Register and conduct outreach to Tribes on how evaluation criteria can be applied to sites of tribal significance and the processes for withholding property locations from the public. Interior generally concurred with GAO’s recommendations to NPS.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of the Interior | The Secretary of the Interior should ensure NPS develops a plan to update its guidance for developing and submitting nominations to the National Register that includes identifying the information that SHPOs and THPOs need in guidance to effectively participate in the program. (Recommendation 1) |
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
|
| Department of the Interior | The Secretary of the Interior should ensure NPS includes steps to enhance the accessibility of its National Register guidance to the public as a part of its plan to revise its guidance. (Recommendation 2) |
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
|
| Department of the Interior | The Secretary of the Interior should ensure NPS conducts outreach to Tribes and THPOs to inform Tribes how properties of tribal significance can be included under the National Register criteria for evaluation, including use of the Traditional Cultural Places bulletin and the best practices update on using criterion A. (Recommendation 3) |
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
|
| Department of the Interior | The Secretary of the Interior should ensure NPS conducts outreach to Tribes to clarify NPS's policies and processes for withholding National Register property locations from the public. (Recommendation 4) |
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
|