Comment on NR Bulletin update

The National Park Service has requested public comments on a proposed update to the “National Register Bulletin: How to Prepare National Historic Landmark Nominations.” (Deadline of May 1, 2017.) I am sharing the comment that I left, which focuses on the need to update the bulletin to move beyond narrow 1950s era thinking about the nature of history to an approach that can incorporate nuanced and conflicted narratives:

The NR Bulletin encapsulates an antiquated, positivistic historical research methodology long abandoned by many historians that places too much emphasis on the role of powerful, influential individuals and too little on common, everyday people in creating what we know as the past. In a similar sense, creating an historical narrative is more than just gathering as many raw facts as possible in a semi-quantitive way of “proving” historical significance. The NR Bulletin needs to recognize that there are many ways to interpret history: as many people have said, the history of the conqueror is quite different than the history of the conquered, yet both narratives seek to uncover a “real” past. They both need to co-exist. The bulletin needs to emphasize the existence of multiple, conflicting narratives of history as normal and encourage these more nuanced versions of significance and abandon trying to find the “real” past as a singular narrative.

I would also highly encourage the NPS to collaboratively involve outside historians to help craft the NR Bulletin in a way that incorporates a post-modern, contemporary approach to history that is sorely needed for the 21st century.

While I would like to see the whole NR criteria revisited altogether, I realize that this request would be beyond the scope of the NR Bulletin re-write, so I will assume, from the NPS’s perspective, that what is significant about the older built environment can only be described by the objective, physical documentation of fabric and the collection of historical facts. (Of course this misses huge areas of contemporary experiential and sociocultural meanings that people also have for older places, but small changes are better then none.) I encourage my readers to also share your comments/thoughts before the deadline.

2 thoughts on “Comment on NR Bulletin update

  1. Thomas King

    Thanks for alerting us to this, Jeremy. Here are the comments I’ve just filed:

    Why not seize this opportunity to re-think the NHL program? It’s really been an anachronism since 1966 when the National Register was created, and maintaining two separate lists (if one must have lists at all) is wasteful and burdensome on the public.

    I suppose you must keep the NHL program, since it’s embedded in law – though a recommendation that Congress consider repealing it would be welcome – but at least you should be able to structure a relationship with the National Register (assuming that IT must be kept) that’s simpler and more rational than the current one.

    Why not delete all the content of the current bulletin and replace it with the simple provision that anyplace found eligible for the National Register can be an NHL if the Secretary determines that it is “significant at the national level” (silly as that notion is, since it too is embedded in law). Then lay out some standards that the Secretary will use in making such a determination. Develop these standards in real consultation with a wide range of stakeholders — including not only the professional practitioners who deal with history, archaeology, architecture and the like, but also those who think (for whatever reasons) that their special places ought to be NHLs and those affected by NHL designation – if anyone actually is.

    Yeah, I know, a nutty idea.

  2. Amanda

    Jeremy, i like a lot your comments and ideas about this subject.

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