GAO urges NPS to overhaul National Register guidance for states and tribes

The Government Accountability Office released a report that contains four recommendations directing the Secretary of the Interior to require the National Park Service to develop a plan for updating its National Register nomination guidance, improve public accessibility of that guidance, and conduct outreach to tribes on applying evaluation criteria and on withholding property locations. The recommendations bind the National Park Service and, by extension, state historic preservation officers (SHPOs) and tribal historic preservation officers (THPOs) who rely on the guidance.

GAO interviews with SHPO officials revealed that key NPS guidance documents are outdated and lack information needed for efficient nominations, forcing agencies to expend additional time and resources. NPS officials acknowledge the need for updates but have not yet created a plan to identify the specific information SHPOs and THPOs require. GAO also heard from tribes that the National Register's evaluation criteria are difficult to apply to tribal sites and that uncertainty remains about protecting sensitive locations from public disclosure.

The four recommendations are: (1) develop a plan to update nomination guidance that identifies SHPO and THPO information needs; (2) include steps to enhance guidance accessibility; (3) conduct outreach to tribes on applying criteria, including the Traditional Cultural Places bulletin and best-practice updates for criterion A; and (4) conduct outreach on policies for withholding property locations. All four recommendations are listed as open.

GAO's review examined relevant statutes and regulations, analyzed NPS guidance, and interviewed NPS officials, nine SHPO offices and eight federally recognized tribes to capture variation in listings from 2019 through 2024 and geographic diversity. The Department of the Interior has generally concurred with the recommendations, and GAO will track agency actions.

The report underscores the need for a coordinated effort to ensure the National Register reflects the full spectrum of America's historic and archaeological resources while addressing the practical concerns of state and tribal partners.