Uncovering Structural Racism in Federal Preservation Policy: Racial/gender/professional purity

What is structural racism in relation to governmental policy?

Since the rise of the Black Lives Matter Movement, there has been increasing discussion on the role of structural racism in public policy. But, what exactly is structural racism in this context? Bailey et al. (2021) offer a concise definition that describes how laws, rules, and “practices” that are “sanctioned” by government perpetuate racial inequality:

All definitions make clear that racism is not simply the result of private prejudices held by individuals, but is also produced and reproduced by laws, rules, and practices, sanctioned and even implemented by various levels of government, and embedded in the economic system as well as in cultural and societal norms. Confronting racism, therefore, requires not only changing individual attitudes, but also transforming and dismantling the policies and institutions that undergird the U.S. racial hierarchy.

While no policy, implemented by government, is free of bias, there is a known relationship between the age of the policy and the degree to which it contains—from a contemporary perspective—increased levels of racial, ethnic, gender, sexual, and ability biases. Such is the case with federal historic preservation policy which has not changed, in any significant way, in about a half century. More specifically, in reference to the two federal policies this article will discuss, the regulation behind the National Historic Preservation Act was finalized in 1969 and guidelines for its implementation were fixed in place by the mid-1980s; the regulation behind the Secretary of the Interior’s Standards was finalized in 1977 and guidelines for its implementation were fixed in place by 1983.

Thus, as a product of their time, the National Register of Historic Places and the Secretary of the Interior’s Standards were created in an era that had substantially higher levels of racial and ethnic discrimination than exists today; moreover, these policies were created and implemented during a time in which white privilege was very much normalized in society. Although the issue still exists, today, in the 1960s and ’70s, government policy was created by and for people in the dominant racial and socioeconomic groups. To be more specific, during the creation of federal preservation policy, there was little concern for the representation or protection of the heritage of people from marginalized groups or who had minoritized identities.

Today, while there is much better recognition of the plurality of the peoples of this country and their heritage values, the federal historic preservation program is still operating under a policy machine that perpetuates mid-century biases. While the 1992 amendments to the National Historic Preservation Act helped to empower Indigenous peoples, primarily through recognizing the authority of tribal governments, the implementing regulations for the National Register and the Secretary of the Interior’s Standards did not change in a corresponding way to recognize the divergent values and meanings held by Indigenous people for their own heritage (for more info on this issue, see Milholland [2010]). The essential social justice issue is that the values and meanings contained in National Register criteria (i.e., significance and integrity) and the Secretary of the Interior’s Standards (how historic buildings should be treated) are exclusively the values of highly educated, white, men who upheld Western norms from the early to middle of the twentieth century.

How were the National Register of Historic Places and the Secretary of the Interior’s Standards created?

First, some brief history for those who are not familiar with the creation of the National Register criteria and the Secretary of the Interior’s Standards.

As has been well documented by Lee (1950), Glass (1990), Mackintosh (1986), and Sprinkle (2014), the criteria for significance and historical integrity were already well developed in the National Park Service by the early 1950s. In 1966, a group of seven white men and a white woman made some minor changes to these existing definitions and recommended their adoption into a regulation, which was finalized in 1967 and officially published in the Federal Register in 1969. Again, the National Park Service, all state historic preservation offices, and the majority of local municipalities in the US currently use these criteria that were fixed in place sixty years ago (for more info on local municipalities’ uncritical adoption of federal policies, see Avrami et al. [2018]).

W. Brown Morton, III wrote, as the primary author, the Secretary of the Interior’s Standards in 1976 and they were finalized in 1977. In an oral history interview, Morton indicated that the Standards were a direct translation of the international Venice Charter of 1964 into an American context (Hudgins 2012).

At no point in the development of the National Register criteria or the Secretary of the Interior’s Standards was the process opened for public input or debate. While early drafts of these documents were shared with National Park Service employees and employees of state historic preservation offices, the creation and finalization of these standards was closed to public scrutiny; it was an invitation-only process to an exclusive group of government employees who were already charged with implementing federal preservation policy.

Mapping bias in the National Register and the Standards: Who contributed to creating these policies?

While many authors, such as those cited previously, have explored the genesis of federal preservation policy, comparatively little has been published on the demographics of the people who created these policies. What was their race, gender, educational level, and area of expertise? In other words, what kinds of social, cultural, and power norms did these people bring to the table when creating the various theories, doctrines, and finally, policies that embodied these theories and doctrines? While it would be erroneous to assume that just because these individuals worked in the relatively distant past that they have inherent racial or gender biases, it is reasonable to assume that they would be prone to perpetuating sociocultural norms in their discussions and writings. Undoubtedly, some of these individuals would have been quite progressive and egalitarian, for the day, and others not as much. The point in this investigation, therefore, is not to focus on specific individuals, but their characteristics in aggregate. While there are a few individuals who have documented racial and ethnic biases, most appear to not be in this category.

The method that I used in gathering these data was to only collect information from individuals with the following characteristics:

  • They had the power and, relative to the era in which they lived, socially recognized expertise to make theory, doctrinal, and policy recommendations and/or the implementation of these policies that were directly relevant to historic preservation/built heritage conservation;
  • The influence and action of these individuals are well documented by other researchers and cited frequently in the literature;
  • These individuals are recognized authors or co-authors of the recommendations and/or policies they have made that contributed to historic preservation/built heritage conservation.

Thus, using this methodology, while Lady Bird Johnson played a pivotal role in helping to pass the National Historic Preservation Act of 1966, no scholars have indicated that she contributed to the theoretical, doctrinal, or specific policy debates in historic preservation and she has no publications, with her name as an author, that documents such contributions. Similarly, while Jane Jacobs has played a very important and pivotal role in urban planning and preservation practice, during the 1960s, when much of the finalization of National Register policy was being made, her contributions to the planning field were not yet widely recognized; it was only later that her importance was finally recognized, as it should have been, originally. Unfortunately, no scholar has recognized Jacob’s work in connection with the development of federal historic preservation policy.

I fully recognize that it is possible that other people who did not publish their contributions to preservation theory, doctrine, or policy and possibly participated in these areas, but their contributions were not recorded by others, are being missed. On the other hand, from the mid-nineteenth century to the early 1970s, the likelihood that women and people with minoritized racial and ethnic identities would have been welcomed in these discussions seems somewhat improbable, unfortunately. Perhaps the best example of this is that in the seven member team that the National Park Service assigned to create the significance and integrity criteria for the National Register, the only woman, of the seven, served as the “secretary” (Kathryn [Kay] Thomas); I include her in these data as it seems likely that in her role in recording information, she undoubtedly was able to make significant contributions.

The results

Using this methodology, I identified 94 people who contributed to the development of the National Register of historic places criteria and the Secretary of the Interior’s Standards. They are listed in the table below. There were very different groups of people who contributed to each of these policies. Far more historians were active in the creation of the National Register than in the Standards; the development of the Standards was largely led by architects and art conservators.

Generally speaking, the direction of influence in the creation of the National Register and the Standards progressed as follows:

positivistic historians –> National Park Service historians –> National Register criteria

art critics/architects –> Italian school of critical and scientific restoration –> Venice Charter –> Standards

These data, which are visually summarized, below, empirically show that the people responsible for developing today’s National Register criteria and the Standards:

  • Were nearly all white men;
  • Were highly educated with an unusually large number (especially for the time) of people with doctoral degrees and who taught in universities;
  • Often held degrees from elite universities;
  • Over-represented the disciplines of architecture and history while under-representing archaeology;
  • Had no representation from the social sciences (e.g., anthropology, sociology, psychology);
  • Had no representation from other kinds of humanities, including racial or ethnic studies;
  • Have some documented racial and ethnic bias.

Why is this important?

When I have shared some elements of this study with others, a frequent comment is that this is all “old history” and is therefore not relevant, today. I have been told “we’ve moved on” and that this investigation is just not relevant to what people in government do today. But, such critiques ignore the fact that hundreds of local, state, and federal government employees in the US regularly mandate the use of the National Register criteria and the Standards from everything from Section 106 reviews to tax credit projects and design review. Every time a government employee takes this kind of action, they are perpetuating the half-century old values of the 94 people that I have identified, including twelve people who have documented racial or ethnic biases. This is not “old” history; this is how ancient government policy brings a potentially deeply biased past to present, and the public, on a daily basis, and in doing so, sustains structural racism.

Or, in another, more critical sense, government employees implementing preservation policy are called upon, in their daily duties, to colonize the values held by Indigenous people, African American people, Asian American people, Latinx people, and People of Color who were excluded, long ago, from the discussion on how significance and integrity should be defined or the appropriate treatment of “historic” buildings. This is wrong and the social injustice inherent in this practice needs to be recognized and rectified by policy leaders.

What’s the solution to this problem? The National Register criteria and the Standards need to change in a way that incorporates the pluralistic values of the American people. And, such changes must be opened to participation from the American public with special efforts to include voices that have long been marginalized in federal preservation policy. Some important questions to ask include:

What would these policies look like if the Tribal Nations in this country were to re-write them?

What would these policies look like if specific, marginalized groups were to re-write them?

What would these policies look like if social scientists were allowed to re-write them?

The ball’s in your court, leaders from the National Park Service.


Avrami, E., Leo, C.-N., & Sanchez, A. S. (2018). Confronting exclusion: Redefining the intended outcomes of historic preservation. Change Over Time: International Journal of Conservation and the Built Environment, 8(1), 102–120.

Bailey, ZD, Feldman, J, Bassett. (2021). How structural racism works — Racist policies as a root cause of U.S. racial health inequities. New England Journal of Medicine 384:768-773.

Glass, J. A. (1990). The beginnings of a new national historic preservation program, 1957 to 1969. Nashville, TN: American Association for State and Local History.

Hudgins, C. (2012). Interview of W. Brown Morton, III. Charleston, DC: Clemson Historic Preservation Program.

Lee, R. F. (1950). Historical and architectural monuments in the united states. Washington, D.C.: National Park Service.

Mackintosh, B. (1986). The National Historic Preservation Act and the National Park Service: A history. Washington, DC: National Park Service.

Milholland, S. (2010). In the eyes of the beholder: Understanding and resolving incompatible ideologies and languages in US environmental and cultural laws in relationship to navajo sacred lands. American Indian Culture and Research Journal, 34(2), 103-124.

Sprinkle, J. H. (2014). Crafting preservation criteria : The national register of historic places and american historic preservation. New York: Routledge.

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