March 21, 2024 | Main Street and Preservation Policy: Understanding the Advisory Council on Historic Preservation’s Report on Federal Historic Preservation Standards | Kelly Humrichouser, Director of Government Relations |
Downtown Toccoa, Georgia. Photo by Steph Maley.
Historic Preservation is embedded in the work and goals of Main Street programs. Understanding federal preservation policy – which reaches the local level in many ways – is important to build thriving downtowns and neighborhoods. A new report from the Advisory Council on Historic Preservation (ACHP) proposes revising and updating preservation policy to respond to changing community needs.
A History of Preservation and Main Street
Main Street America was initiated as a program of the National Trust for Historic Preservation to bring life back to disinvested buildings in downtown areas. That commitment to preservation continues in building rehabilitations, facade improvements, and engagement with history – both difficult truths and points of pride – in communities across the network. We see the innate value in uplifting and expanding on existing community assets, both in the built environment and through stories, memory, and culture. Preservation is a core tool within the Main Street Approach, our methodology for economic development of downtowns and neighborhood commercial districts. Main Street leaders seek to enhance downtown buildings and ultimately create economic impact. Through state and federal historic tax credits, rehabilitation of existing buildings provides space for entrepreneurs, civic functions, and residential development. Working with the Certified Local Government program and local historic commissions, Main Street leaders use historic preservation to enhance the physical environment and to attract residents and visitors.
Preservation as a Tool for Community Growth
Main Streets utilize preservation tools with the goal of creating economic and social benefits for communities. But the work and concerns of Main Street have expanded and changed to reflect a broad set of community concerns including entrepreneur support and business succession, housing availability and affordability, and streetscape and infrastructure improvements.
Grappling with the economic and social needs of different communities requires a delicate balance with historic preservation. At times, we must consider how preservation policies and processes function to support our broader community-identified goals and align with program strategies. Main Street leaders have encountered barriers to creating housing on upper floors, subdividing existing spaces for 21st century entrepreneurs, or supporting accessibility when working through preservation processes. While these preservation processes do include remedies, in many communities, the transactional costs and capacity to participate in these remedial steps may limit the impact of preservation tools.
Recommendations for Realigning Preservation Policy
Recent activity at the federal level has focused on how preservation standards can work better for all, including for Main Street programs. This month, the Advisory Council on Historic Preservation (ACHP) released a report with recommendations for the preservation field related to preservation policy. The ACHP is an independent federal agency tasked with overseeing elements of federal preservation policy, including the Section 106 process, and providing feedback to the Administration and Congress.
ACHP’s report focuses on the Secretary of the Interior’s Standards, a set of criteria established by the National Park Service for the rehabilitation of historic properties. The Standards form the basis of preservation policy at state and local levels, as well. In Main Street, the Standards are used extensively through the work of local preservation commissions, in verification of federal and state historic tax credits, and written into Main Street design guidelines. But the Standards have not been updated in twenty-nine years.
The ACHP report includes feedback from years of regulatory advocacy from within the preservation community, and a specific comment period during the summer of 2023. As part of our efforts to advocate for the Main Street network, Main Street America offered feedback during this comment period, which is compiled as part the ACHP Report.
ACHP made recommendations focused on economic impact, housing, sustainability, and equity based on the comments they received from Main Street America and others. These recommendations include a call for more clarity, more education, and more access to information regarding the Standards, particularly in their application for tax credit projects. The report also suggests a larger change that could have a substantial impact on Main Street: grading the National Register of Historic Places, a suggestion previously advanced by Main Street America Senior Advisor Patrice Frey. This recommendation would substantially change how preservation is governed and can create opportunities for expanding the impact and use of preservation tools in Main Street.
Next Steps
This process is just beginning. The recommendations will require more time, attention, and participation from other federal agencies. But the ACHP’s efforts to influence changes to existing preservation policy align with ongoing conversations throughout the historic preservation community. Efforts like the Preservation Priorities Task Force offer insight into how the historic preservation field aligns with urgent community concerns like housing, equity, and climate. Ultimately, historic preservation is primarily governed through the application of the Standards, and for changes to be meaningful, they must start with these underlying policies.
At Main Street America, we look forward to continued conversations with the ACHP, partners, and the Main Street network on how historic preservation policy can create the most impact for downtowns and neighborhoods, while addressing urgent community needs. If you want to learn more: