06/10/2026
"Framing historic preservation review as responsible for project challenges is a bit like blaming a building inspector for identifying a cracked foundation. The very purpose of consultation is to surface issues early in the process — helping avoid unnecessary harm to historic places and more costly delays later." ~Erik Hein, Executive Director, NCSHPO
The conversation about permitting efficiency should start with one simple reality: most Section 106 reviews move forward without adverse effects or mitigation agreements.
The focus is often on the small number of complex projects, not the thousands of routine reviews completed each year by agencies, applicants, SHPOs, THPOs, Tribes, and other consulting parties.
If the goal is greater predictability, one of the most effective steps Congress could take is ensuring SHPOs and THPOs have the resources to meet this workload.
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National Trust for Historic Preservation
Preservation Action
National Association of Tribal Historic Preservation Officers
ACHP - Advisory Council on Historic Preservation