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Response to the Draft TCP Guidance

The National Park Service has released for comment a revision of Bulletin 38, Identifying, Evaluating, and Documenting Traditional Cultural Places.  While the draft greatly expands the guidance offered to nominating historic places that are important to traditional communities, it is hampered by limits imposed by existing legislation and regulation.  Regardless of how encouraging the guidance is in trying to bring more traditional cultural places (TCPs) into the National Register, nominated places must still fulfill all current existing standards for significance and integrity. In offering this guidance, the authors have also exposed a problem with the entire construct of a traditional cultural place.  In describing what defines a TCP, the guidance fails to show how it should stand separate from other historic places, resulting in a false dichotomy. This dichotomy results in separate guidance, separate terminology, and potentially separate rules for a construct that does not exist in law or regulation.  The immediate answer is to update 36CFR60 to be more in tune with the intent and ever evolving understanding of the National Historic Preservation Act.  Improving the range and diversity of historic places that are recognized by our Nation is a good goal. The proposed guidance does not help.

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