Sunday, March 13, 2011
National Register Documentation
For the first time in several years I am working a group of National Register nominations, the formal documentation that we use to “List” a property as historically significant as opposed to the more internal “Determinations of Eligibility” that generally suffice for what is termed compliance work. DOEs, which are quicker to write and review, are what agencies and regulated entities prepare as part of their Section 106 process. It used to be that the only time you actually “listed” a property was when a private party wanted to secure the various tax benefits available for “listed” resources, or when a city was seeking formal National Register designation of a district. NR documentation isn’t all that different than a DOE, though it has usually been expected to be a little more detailed and formalized. Now, it appears that the DOE process and the NR process are merging a bit, toward simpler, shorter, reports.
Back in the day NR nominations were shockingly brief if not downright terse, often topping out at ten pages including maps and graphics. When I was writing lots of these, in the 1980s and 1990s, they had expanded into a detailed narrative that often included scads of local history if for no other reason than a nomination was obligated to develop a context if it was making the claim that a particular building or property was significant within it. I like to think that nominations from this period serve as valuable sources of information on the historic development of many small towns, or industries that would not otherwise be very well understood. I mean if I was interested in the Walnut industry in southern Oregon during the pre-WWI period, I sure know where I would turn for information.
Well, apparently, NPS and perhaps the SHPOs too, have grown tired of lengthy history and are embarking on an effort to streamline the nomination process, perhaps so that more property owners will feel comfortable in preparing them on their own. That’s fine, though I am not sure that lowering the documentation standards is in anyone’s long term best interests. The national listservs (Forum-L) occasionally have small comments or complaints about fighting NR documentation “creep,” the implication being that those early 10 page nominations had it just about right (if you can’t prove it’s significant in ten pages, then it probably isn’t). I am not so sure that is the right approach and I’m a little bit sorry to see the era of comprehensive documentation end. What do you think?