Dear: Chairman Wilson and Ranking Member Bordallo:

 

As members of the Historic Preservation Caucus, we very much appreciate the value you place in historic preservation and the laws that govern the preservation of our nation’s heritage.  We write to express our strong opposition to H.R. 473, the Military Land and National Defense Act (Military LAND Act) and its adoption as an amendment to the fiscal year 2017 National Defense Authorization Act (NDAA).  Our organizations, as well as other local, state, and national preservation organizations, the Advisory Council on Historic Preservation (ACHP), the National Park Service, and the Department of Defense (DoD) all believe this amendment is unnecessary.

 

Specifically, H.R. 473 seeks to amend the National Historic Preservation Act (NHPA) to prevent designation of federal properties as National Historic Landmarks (NHL’s), World Heritage Sites or as listings on the National Register of Historic Places (NR) when objections are raised based on issues of national security. The legislation also calls for the National Park Service to identify a way to expeditiously de-list federally-owned historic sites when a concern over national security is raised.

 

The current system protects both Cultural Heritage and National Security

Under current law, 16 U.S. Code § 470, federal agencies manage their historic properties while simultaneously protecting America’s national security interests and maintaining military readiness. The NHPA requires federal agencies to identify and care for their historic places, but does not prevent or prohibit federal agencies from managing or maintaining their properties in whatever way necessary to protect America’s national security interests. Today, federal agencies may make substantive non-historically compatible renovations or even demolish historic properties in the interests of national security or for any other mission – even over objections from the public and the Advisory Council on Historic Preservation.

 

According to the National Park Service (NPS), DoD agencies have 415 historic buildings, districts, and sites listed on the National Register of Historic Places. In the nearly 50 years of the National Register program, both the NPS and DoD testified they were unaware of a single instance where a historic designation was perceived to have impaired military readiness or training.

 

DoD Does Not Believe Section 2853 is Needed for National Security

During a hearing in the 113th Congress before the then named House Subcommittee on Public Lands and Environmental Regulations on the Military LAND Act, H.R.3687, DoD stated its position that compliance with the NHPA does not impede military readiness and that the legislation is not needed to preserve access to training and testing sites and facilities. We urge you to weigh carefully DoD’s testimony and reject the impetus to make unnecessary and substantive changes to a law that has successfully fulfilled its purpose for more than 40 years by requiring that federal agencies consider the impact of their actions on historic properties.

 

Since the creation of the National Historic Preservation Act in 1966, our nation has successfully maintained and balanced the interests of national security and our historic resources. Again, we strongly urge you to oppose this unnecessary amendment and to contact us with any questions.

 

 

Sincerely,

American Anthropological Association

American Cultural Resources Association

Coalition for American Heritage

National Conference of State Historic Preservation Officers

National Trust for Historic Preservation

Preservation Action

Society for American Archaeology

Society for Historical Archaeology