Public Architects Committee

I am posting below Illya Azaroff's email, in case you missed it - please respond by this Friday!  

• • Shift decision-making authority almost entirely to federal agencies
  • Limit or eliminate the role of State Historic Preservation Officers (SHPOs), Tribal Historic Preservation Officers (THPOs), Tribes, and local governments in shaping outcomes
  • Curtail public participation and remove preservation organizations and community stakeholders from formal consultation roles
  • Narrow what qualifies as a "historic property," excluding thousands of culturally and historically significant sites
  • Eliminate or weaken requirements to avoid, minimize, or mitigate harm to historic resources
  • Allow agencies to make unilateral determinations through internal reports rather than negotiated agreements using public input

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Ludmilla Pavlova-Gillham FAIA
University of Massachusetts
Amherst MA
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Please save Section 106. This is essential to preserving the monuments that represent our great history and the remarkable geological beauty of this great land. Please do not destroy this so that a family of grifters can sell it off for personal profit.
Sent from my iPhone

There's a lot to consider here. First and foremost we want to save our historic properties in this country. What is the best way to do that? Is the current Section 106 how to do that? Take fifteen minutes to read just some of this article: https://ifp.org/reforming-section-106-of-the-national-historic-preservation-act/ . I consider there to be a lot to be improved and many unintended consequences have been borne of the Section 106 process (see difficulties with large renewable energy projects having to pay for impacts on tourism which has little to do with the impact on historic preservation in those cases). So yes, reform Section 106, but don't do it this way, it's absurd. I advocate writing your Congressman to stop the current action being attempted but I'd say to also ask Congress to have a legislatively mandated process to rewrite Section 106 in a normal way. You never know, maybe both parties could actually get behind this.

My firm has little or no impact either way on this, our Section 106 historic preservation projects usually have little to no issue going through the process. Cumbersome but inconsequential. For others there are impacts.

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Richard Onken AIA
Alesia Architecture
Elkhorn NE
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Thank you for posting the link to the article on reforming Sec.106, Richard.  I found it particularly interesting as it points to the continuing cultural conflicts in land development for vertical and horizontal infrastructure of historic and cultural significance. The changes it proposes might be a good start for debate in the legislative branches of government, but for now it seems that the courts are the only venue where this work may continue.  

As reported by the Washington Post, the ACHP (dominated by appointees of the current administration) said it was moving forward with changes to a federally required process that governs changes to landmarks such as the National Mall, sites that are significant to Indigenous tribes and other properties eligible for listing on the National Register of Historic Places.  The proposed rules "will now move to the interagency review process" overseen by the White House's Office of Management and Budget. Once it clears that review, the proposal will be opened for public comment before being finalized.

The article quotes Sara Bronin, who led the ACHP under the Biden administration: "I expect the ACHP to ignore public comment and finalize the rule in the next month or so... Once they do, the preservation community and its allies will be ready both to challenge their action in court and to ask Congress to intervene."  

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Ludmilla Pavlova-Gillham FAIA
University of Massachusetts
Amherst MA
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Original Message:
Sent: 07-24-2026 06:17 PM
From: Richard Onken, AIA
Subject: Urge your Members of Congress to weigh in with ACHP to save Section 106

There's a lot to consider here. First and foremost we want to save our historic properties in this country. What is the best way to do that? Is the current Section 106 how to do that? Take fifteen minutes to read just some of this article: https://ifp.org/reforming-section-106-of-the-national-historic-preservation-act/ . I consider there to be a lot to be improved and many unintended consequences have been borne of the Section 106 process (see difficulties with large renewable energy projects having to pay for impacts on tourism which has little to do with the impact on historic preservation in those cases). So yes, reform Section 106, but don't do it this way, it's absurd. I advocate writing your Congressman to stop the current action being attempted but I'd say to also ask Congress to have a legislatively mandated process to rewrite Section 106 in a normal way. You never know, maybe both parties could actually get behind this.

My firm has little or no impact either way on this, our Section 106 historic preservation projects usually have little to no issue going through the process. Cumbersome but inconsequential. For others there are impacts.

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Richard Onken AIA
Alesia Architecture
Elkhorn NE
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