Wednesday, April 7, 2010

HHF Recommendations Addressing the State Historic Preservation Division's "High Risk" Status

Re: National Park Service Report on Hawaii State Historic Preservation Division Compliance with annual historic preservation fund grant
  • The National Park Service (NPS) is charged with oversight of the states’ implementation of the nation’s preservation program, primarily through compliance with the terms of an annual Historic Preservation Fund (HPF) Grant, which is provided to the states to implement the National Historic Preservation Act (NHPA).
  • In a report dated March 19, 2010, NPS found that the Hawaii State Historic Preservation Division (SHPD) is not satisfactorily meeting the minimum requirements of its grant and deemed SHPD as a “high risk grantee.” The report outlined corrective actions that SHPD must take to remedy the problems in order to ensure continued eligibility for the program and to retain the state’s approved status to make determinations about federal undertakings that have the potential to affect historic properties.
  • If SHPD fails to make adequate progress on the corrective action plan within a year and to complete the action items within two years, the consequence will be removal of the state’s approved status and loss of its federal funding.
  • The State and Federal historic preservation programs were designed to provide identification and protection of locally and nationally significant historic properties in a way that is harmonious with contemporary use. Failure to have adequate professional staff, standardized processes and effective programs exposes Hawaii’s historic legacy to irreparable harm.
  • Loss of its status and right to make determinations under the NHPA would have a devastating effect on Hawaii. Without an approved State Historic Preservation Office (SHPO), all federal undertakings (including projects with any federal funding, permit, license or approval) will need to use alternative methods for compliance with the NHPA. Since no state has lost its federal status under NHPA since its enactment in 1966, any alternative compliance method is unknown and unprecedented. It would likely involve loss of local control and decision-making, which would be problematic for both adequate protection of the state’s historic resources, and create uncertainty and delays for the proposed projects, which could jeopardize their viability.
  • The loss of approved status will have an economic effect. Major undertakings likely to be affected by this action include such projects as the public-private partnership for military family housing; changes to facilities at the Pearl Harbor Naval Shipyard and other military installations; transportation funding for roads, bridges, airports, harbors and transit; permits processed by EPA and Army Corps of Engineers; and improvements to national parks and wildlife refuges.
  • Historic Hawai‘i Foundation urges immediate support for SHPD to comply with NHPA, the HPF Grant Manual and the Corrective Action Plan, as well as longer-term actions to address root weaknesses in the preservation program.
  • The State should develop a strategy that addresses short-, medium- and long-term solutions:
    • In the immediate future, SHPD needs to address the corrective action items, which are primarily administrative actions requiring internal systemic adjustments and management accountability.
    • In addition, DLNR should convene a strategic discussion with major stakeholders to develop model programs for survey & inventory, preservation planning and certified local governments; public-private partnerships may assist.
    • For the long-term, the State of Hawaii should consider an overhaul of its historic preservation infrastructure in order better to provide appropriate and adequate systems to address both federal and state issues; this community discussion should include a broad base of stakeholders and innovative approaches.
    • The State needs to allow for full use of available resources, including hiring for vacant positions; contracting for services; accepting restricted special donations; and use of in-kind support.