07/24/2026
Southern Research, Historic Preservation Consultants, Inc. was founded over 33 years ago to provide historic preservation and cultural resources consulting services to identify and document historic properties, which include archaeological sites and above-ground historic resources. Much of the work is driven by Section 106 of the National Historic Preservation Act of 1966. This act established the National Register of Historic Places (NRHP) and created a State Historic Preservation Office (SHPO) for each state and the national Advisory Council on Historic Preservation (ACHP). Section 106 calls for federal agencies to take into account the effect that their actions (via funding and/or permitting) have upon significant historic properties for a given project. It is designed to identify significant historic properties that need protection and/or mitigation from impending damage and/or destruction from a proposed action. This involves not only conducting field surveys, but consultation with the SHPO, Tribal Historic Preservation Offices (THPO), local historical societies and organizations, and interested members of the public to identify such properties. The identified resources are then evaluated to determine if they are eligible for listing in the NRHP. The SHPO reviews and provides comments on the findings of projects in their state. The current Section 106 process allows for input from the public and interested parties, meaning that the locals and interested parties have a say in a collaborative process.
The proposed changes to Section 106 will gut the current process. The changes remove the requirements to avoid, minimize, or mitigate impacts to significant historic properties. They change the definition of consultation and drastically limit the scope of consultations, effectively cutting out the SHPOs and THPOs. The proposed changes will allow agencies to decide to simply not assess the effects of their actions on significant historic properties. As a result, historic properties, both in the ground and above ground, will be damaged and destroyed. Tens of thousands of historic preservation professionals stand to lose their jobs.
Contrary to what some people may believe, Section 106 rarely stops projects. It can take time, and the process should be improved to make it more efficient. But the current revisions simply throw the baby out with the bathwater by dismantling the process. These changes will lead to chaos and confusion in the process and will cause delay and litigation. More importantly, it will put portions of our history at risk of being damaged and/or destroyed because the archaeological and historical work will not be done as it should be. People’s ancestors who lay in lost and overgrown cemeteries will be unknowingly bulldozed into spoil piles; Civil War earthworks and battlefields will be razed; Native American mounds and villages will be leveled.
People have been in this country many thousands of years, and as a result we have a deep, rich history that is all of ours to share in. Georgia alone has nearly 65,000 documented archaeological sites, with more being added daily. Over the coming month we will be sharing examples of what we have learned as a result of the current Section 106 process.
Unfortunately, the proposed changes are expected to be approved by the ACHP, with the voting deadline today, Friday, July 24. However, you have a chance to provide public comment on the proposed changes when they go on the Federal Register. We will provide a link to that once it is available.
Since the enactment of the National Historic Preservation Act 60 years ago, Section 106 has been the foundational requirement for federal agencies to “take into account” the effects of their actions on historic properties and places. The Advisory Council on Historic Preservation has proposed rev...