On February 26, 2016, the Advisory Council on Historic Preservation (ACHP) published a new draft policy statement on Historic Preservation and Community Revitalization seeking comments from the public. We appreciate the ACHP’s recognition of the important connections between preservation and community revitalization. We share the goal of empowering federal, state, and local governments to achieve revitalization goals while promoting the reuse and rehabilitation of historic properties.

However, the policy statement needs to go further in clearly describing the issues involved and charting a clear path forward for federal, state, and local government agencies and partners in this essential work. We urge the ACHP to revise the policy statement so it can play a stronger role in addressing the major challenges facing historic buildings and neighborhoods in America’s legacy cities. We invite any preservationists and legacy city allies with an interest in this topic to consider our response and share your own comments with the ACHP by this Monday, April 4, 2016.

The ACHP is an independent federal agency that advises the President, Congress, and federal agencies on national historic preservation policy. The foundation for the current policy statement was laid in March 2013 with the ACHP’s report Managing Change: Preservation and Rightsizing in America (PDF). To build on this publication, the agency organized a working group in December 2014 whose comments over the past year have helped to inform the proposed policy statement.

What is our response to the policy statement?

The policy statement consists of ten principles presented as “sound guidance to assist communities in their efforts to incorporate historic preservation into project planning”:

  1. Historic preservation values should be considered in the revitalization of both rural and urban communities.
  2. Historic preservation should be incorporated in local planning for sustainability, smart growth, and community resilience.
  3. Historic property surveys, including those in historic districts, are tools that should be used by communities to provide for federal, state, and local planning and revitalization projects.
  4. Effective citizen engagement allows community residents to identify resources they care about and share their views on local history and cultural significance.
  5. Indian tribes may have an interest in urban and rural community revitalization projects that may affect sites of historic, religious, and cultural significance to them.
  6. Private resources can contribute to local revitalization efforts and leverage public funds.
  7. Tax credits can be used to promote historic preservation projects that preserve local assets.
  8. Early consideration of alternatives to avoid or minimize adverse effects to historic properties is essential to ensure proper integration of historic properties in revitalization plans.
  9. Development of flexible and programmatic solutions can help expedite historic preservation reviews as well as more effectively and proactively address situations involving recurring loss of historic properties.
  10. Creative mitigation can facilitate future preservation in communities.

While there is little to disagree with in the ten principles, they each must be stronger and more focused to be useful to their intended audience. We have three major concerns:

  • The policy statement does not clearly explain the relationships between historic preservation and community revitalization. Without clear definitions of these terms and their meaning from the ACHP, the statement and its principles are difficult for government agencies or local preservation advocates to leverage into action.
  • The policy statement does not explore the feasibility of these principles  through examples. We know that innovative work is going on around the country at these intersections between preservation and revitalization. This statement is an opportunity to highlight those examples for leaders in public service and explore how federal, state, and local agencies can play a more active role.
  • The policy statement does not consider the present context for preservation and revitalization. For example, recommending surveys and inventories does not help the many states and local governments that have seen major decreases in funding over the past decade. CLG staff are cited as a resource, but many communities—particularly those struggling with long-term population loss—lack the funding to hire specialized staff; indeed, some communities have a one-person planning department. And recommending tax credits does little for properties located in disinvested urban neighborhoods with limited access to private lending. We agree that preservation can and does play a significant role in community revitalization, but the policy statement will be most compelling and useful if the structural challenges facing legacy cities and other distressed communities are fully acknowledged.
Buffalo, 2011. Photograph by Cara Bertron.

Buffalo, 2011. Photograph by Cara Bertron.

What else could the ACHP be doing?

What is the alternative for the ACHP? We ask this policy statement to:

  • Acknowledge the immense scale of challenges surrounding vacant and distressed historic buildings in communities across the United States, from Baltimore to Detroit to Chicago to St. Paul.
  • Provide clear direction and informational resources for the overburdened and under-resourced staff dealing with these issues in state and local government, along with the many nonprofits and private developers who are affected by preservation policy.
  • Identify the legislative and rule-making hurdles presented by federal and state policies for historic preservation and other areas, including 1) the diminished “integrity” of many historically disinvested neighborhoods and 2) the increased measures and costs required to meet the Secretary of the Interior’s Standards on rehabilitation projects.

How can you share your comments?

If you share our concerns or have other questions of your own, we encourage you to submit your own comments on the ACHP Policy Statement on Historic Preservation and Community Revitalization by email to Rightsizing@achp.gov by April 4, 2016. For questions about the statement, you can contact Charlene Dwin Vaughn, Assistant Director, Office of Federal Agency Programs, Advisory Council on Historic Preservation at 202–517–0207.


Cara Bertron
Chair, Preservation Rightsizing Network

Emilie Evans
​Secretary, Preservation Rightsizing Network
​Director, Rightsizing Cities Initiative, PlaceEconomics

Eli Pousson
Leadership Team Member, Preservation Rightsizing Network
Director of Preservation & Outreach, Baltimore Heritage

Melissa Jest
Leadership Team Member, Preservation Rightsizing Network
Manager, Historic Properties Redevelopment Program, National Trust for Historic Preservation

Nicholas Hamilton
Leadership Team Member, Preservation Rightsizing Network
Director of Urban Policy, The American Assembly
Director, Legacy Cities Partnership