I. INTRODUCTION

The National Park Service (NPS) has been increasingly called upon by Congress to conduct feasibility studies on discreet areas throughout the Nation that may be candidates for National Heritage Area (NHA) designation. The NPS has not previously had guidance documents or management policies for undertaking NHA feasibility studies available for reference by NPS personnel or others performing such studies. These guidelines provide a suggested methodology, including basic steps or areas of inquiry, that make up a comprehensive NHA feasibility study; how to apply NHA criteria; an outline of a typical NHA feasibility study report; and, appendices containing helpful hints on sources of information, public involvement techniques, and other factors.

National Heritage Area designations have been initiated in four different ways outlined below, although recently, most are the products of congressionally authorized feasibility studies, special resource studies, or direct congressional designation without prior studies being undertaken.

1. The 1998 Omnibus Parks Management Act (Public Law 105-391) establishes certain requirements for studies of areas for potential addition to the National Park System. Similar requirements are established by law for studies of Wild and Scenic Rivers and additions to the National Trail System. Studies of new units of the National Park System, Wild and Scenic River System and National Trail system can only be initiated if authorized by Congress. Based on NPS study team professional judgements, the potential for national heritage area designation has been evaluated as a preferred management alternative in a number of these congressionally authorized studies. Chapter 1 of Management Policies and special directive 92-11 guide studies of potential new NPS units.

2. Congress has specifically authorized feasibility studies of potential new heritage areas independently from any consideration of creating a new unit of the National Park System, National Trails System, or Wild and Scenic River System.

3. Congress has directed funding from the NPS budget to studies of potential heritage areas without any specific authorization.

4. Local sponsors have undertaken a number of NHA feasibility studies, either as part of a state sponsored heritage initiative or because a local management entity desires to seek NHA designation by Congress. NPS may be asked to evaluate the locally sponsored feasibility study to determine if the candidate area qualifies for national designation.

These guidelines are designed to help understand the process and content of NHA feasibility studies regardless of whether the study is congressionally authorized or undertaken by local sponsors. A first step in any study process undertaken by NPS personnel, of course, should be to review the legislative history on how it was authorized or directed.

The guidelines are offered with the understanding that each study may involve unique resource and public involvement issues and each region may present different study opportunities and constraints. As a suggested study process, flexibility in the use of the guidelines is assumed throughout the following discussion. Study team members may also find that altering the sequence of the study steps better serves their purposes.

On October 26, 1999, in testimony before the House Subcommittee on National Parks and Public Lands, House Resources Committee, the NPS articulated its definition of a NHA, the steps to be completed prior to designation, and 10 criteria to permit the NPS, Congress and the public to evaluate candidate areas. While the legislation that was the subject of the original testimony did not become law, NPS has reiterated the value of these criteria in subsequent testimony on bills proposing NHA designations. The NPS definition provides that:

The testimony continued:

The focus is on the protection and conservation of critical resources; the natural, cultural, scenic, and historic resources that have shaped us as a nation and as communities.

In national parks, it is primarily the responsibility of the National Park Service to ensure that the resources that the Congress has recognized as being important to our nation's heritage are protected, interpreted and preserved. In heritage areas it is the responsibility of the people living within a heritage area to ensure that the heritage area's resources are protected, interpreted and preserved and it is the National Park Service's responsibility to assist them in that endeavor.

Our experience working with heritage areas around the country has led us to the recognition that the people who live on the land are uniquely qualified to protect it. Heritage area designations provide significant opportunities to encourage citizens, local businesses and organizations, and local governments to work together to foster a greater sense of community, to reward community pride, and to care for their land and culture. As Aldo Leopold once said, 'When we see land as a community to which we belong, we may begin to use it with love and respect.' Heritage areas provide the opportunity to pass on the knowledge and culture of the past to the future. As Loren Eiseley said, 'Without the past, the pursued future has no meaning.' By creating this bond with the next generation, heritage areas will be insuring their continued support into the future.

The conservation of resources through local initiative has shaped our thoughts on heritage areas and how best to identify, designate and then support them. Probably the most important work that goes on in a heritage area is the organizing that goes on at the beginning of the process. The recognition of important local resources, the determination of a community's unique story, the formulation of a plan involving all parts of a community in how best to protect those resources and to carry on a community's heritage through each generation are the difficult tasks. These are arduous and time-consuming activities, but our experience tells us that through them there are created strong local commitments to the conservation of a community's heritage and its unique resources that help to define communities and result in vital, thriving communities.

In many cases, the feasibility study is a part of the organizing influence that begins the process. As such, these studies are quite different from others normally conducted by the NPS. They require an understanding on the part of the study team that they are interacting in a wider community environment. Pivotal decisions relating to NHA designation rest on the support, commitment and capacity of those in the community that will be responsible for undertaking and implementing a heritage area management plan. Providing the opportunity for the articulation of local visions and suggestions of how heritage area programming may best be implemented provides opportunities for the community to better understand the role of a heritage area. This is a critical element in assisting the study team to measure the potential for local support, capacity, commitment, and ultimately, NHA feasibility

Four steps are necessary before the Department of the Interior makes findings and recommendations to Congress regarding designation of a region as a NHA:

1. completion of a suitability/feasibility study;

2. public involvement in the suitability/feasibility study;

3. demonstration of widespread public support among heritage area residents for the proposed designation; and

4. commitment to the proposal from the appropriate players which may include governments, industry, and private, non-profit organizations, in addition to the local citizenry.

The NPS listed ten interim criteria for evaluation of candidate areas by the NPS, Congress and the public:

1. An area has an assemblage of natural, historic, or cultural resources that together represent distinctive aspects of American heritage worthy of recognition, conservation, interpretation, and continuing use, and are best managed as such an assemblage through partnerships among public and private entities, and by combining diverse and sometimes noncontiguous resources and active communities;

2. Reflects traditions, customs, beliefs, and folklife that are a valuable part of the national story;

3. Provides outstanding opportunities to conserve natural, cultural, historic, and /or scenic features;

4. Provides outstanding recreational and educational opportunities;

5. The resources important to the identified theme or themes of the area retain a degree of integrity capable of supporting interpretation;

6. Residents, business interests, non-profit organizations, and governments within the proposed area are involved in the planning, have developed a conceptual financial plan that outlines the roles for all participants including the federal government, and have demonstrated support for designation of the area;

7. The proposed management entity and units of government supporting the designation are willing to commit to working in partnership to develop the heritage area;

   

8. The proposal is consistent with continued economic activity in the area;

9. A conceptual boundary map is supported by the public; and

10. The management entity proposed to plan and implement the project is described.

III. SUGGESTED STEPS IN A NATIONAL HERITAGE AREA FEASIBILITY STUDY

The steps described below should be sufficient to undertake a comprehensive NHA feasibility study by NPS personnel. They are also encouraged for use in feasibility studies undertaken by local organizations seeking National Heritage Area designation. The study team should feel free to reorder the steps to best fit the circumstances of the study.

NPS conducted NHA feasibility studies are subject to the compliance requirements of the National Environmental Policy Act (NEPA), Section 106 of the National Historic Preservation Act and Section 7 of the Endangered Species Act. Generally, an Environmental Assessment (EA) is sufficient to meet NEPA compliance. NHA Feasibility Studies undertaken by local interests, independent of congressional authorization or NPS involvement, normally have not included an EA even if NHA designation will be sought as a result of the study. Because at this stage in the evolution of a heritage area specific programs and projects may not be known, a note should be included in any study that upon designation, NEPA and Section 106 compliance work will be required not only for a heritage area management plan for the region, but also for all future projects requiring federal funding.

An Environmental Impact Statement (EIS) may be required for an NPS conducted study if significant, quantifiable positive or negative impacts are identified. Required consultation with State Historic Preservation Officers (SHPOs), the US Fish and Wildlife Service and American Indian tribes and tribal organizations must be undertaken.

A. Step 1 - Defining the Study Area

Where the study area is not specified or apparent at the beginning of the study, a process for determining an appropriate region needs to be developed by the study team. The objective of the process should be to identify natural, cultural and/or political limits that best encompass important resources related to the history of the region and potential themes that may be identified. Public involvement in delineating the study area can be of important assistance and serve to promote future public acceptance and support for potential heritage area boundary alternatives proposed in the study.

B. Step 2 - Public Involvement Strategy

An effective public involvement strategy is based on the assumption that a successful NHA study can only be achieved with the active participation of affected interests in the region. Indeed, the interim criteria require findings of public support and commitment to heritage area designation. The objectives of a public involvement strategy should normally include:

1. promotion of public understanding of the study and its components;

2. maximization of participation and contributions of interested and affected governments, organizations and individuals in the study process; and
   
   
   
3. assessment of public support for designation, and local capacity and commitments to successfully undertake heritage area resource protection and programming.

Elements of the strategy may include a process for identifying stakeholders, extensive individual and organizational outreach, workshops and meetings, written materials (meeting handouts, brochures, newsletters, and press releases), a web site, and the use of surrogate methods (e.g. asking other organizations, web sites and publications to inform the public of the study, request information on historical research, resources that exist within the study area and potential themes that may be considered, etc.). Workshops and charrettes are particularly useful in permitting the public to assist in the identification of regional resources, potential heritage area themes and in creating their own vision of the region's future. Appendix 2 provides sources of information on public involvement strategies and techniques that can be adapted for NHA study purposes.

Public workshops associated with the conduct of a NHA feasibility study often provide an opportunity for the NPS to facilitate a regional or community vision of a NHA. Visioning workshops are a vehicle to bring interested publics together to discuss and describe desirable futures and the roles that each may play in their achievement. Visioning workshops are useful, too, in promoting an understanding of how resource protection, interpretation and economic development may be compatibly undertaken. The process better permits the public to determine if a NHA designation would be useful in achieving community goals and to understand what actually occurs in a NHA.

C. Step 3 - Determination of the Region's Contribution to the National Heritage and Development of Potential Themes

The study team should assemble historical information about the region and understand the contributions of the study area and its people and events to the national story. These have varied considerably among existing heritage areas. Some represent specific historic events leading to the formation and development of our nation, or early industrial or technological achievements that fashioned today's society. Some are based on specific cultural groups in a given region. Others celebrate important landscapes that were the focus of literature, art and social experimentation. Famous persons are often honored, as well as the contributions of immigrants, early settlers, woman, labor, African Americans, Native Americans and others whose experiences and contributions are important for understanding the nation's heritage.

By first determining the region's contributions to our national heritage, the study team may better focus its work on identifying the natural and cultural resources associated with those contributions and the themes that may best enable the public to understand, appreciate and celebrate their importance. One potential element in determining if a region contributes to the national heritage is the presence of a related National Park System unit (National Park, National Trail or Wild and Scenic River), and National Historic Landmarks and National Natural Landmarks within the study area.

Most often, knowledgeable experts and the public are able to contribute significant information to the study team about source materials and persons familiar with the history of the region, events of importance, historical figures and the contributions of various communities. Tapping into and synthesizing this knowledge is a key to capturing the true picture of the region's contributions and the community's view of its shared heritage. A round table of experts can assist the study team in evaluating the role and importance of the region as it relates to comparable landscapes in other parts of the country and potential stories that may constitute viable themes. The team may also wish to consult the 8 themes contained in the 1996 NPS Thematic Framework as a starting point in theme development.

The study team should also ascertain information about traditions, customs, beliefs, and folk life that characterize the region (criterion 6). The traditions, customs and beliefs may or may not exist in today's society. Many that don't are celebrated by local festivals, exhibits and through other commemorative events. Identifying the ways in which these important aspects of heritage are still evident, shared, or celebrated through commemoration are necessary elements in understanding the region's history and contributions. The analysis should assist the team in discovering whom in the community shares a common culture that is important to the region's story and if it continues to the present day.

Themes are the organizing framework within which interpretation of related natural and cultural resources is conducted. They are the bridges to increased public understanding of the importance of the region and its theme-related resources. NHA themes are derived from analyses of the region's contributions to our national heritage. They represent the broad stories that integrate the collection of individual resources so that they may be viewed within the context of the whole.

A good NHA theme structure enables residents and visitors to understand the region's overall contributions to our national heritage and the elements that enabled them to occur. The elements may include, among many other factors, natural and cultural resources, important events or decisions and the roles of specific places, people, social movements, beliefs, folkways and traditions.

The study team should understand that themes developed during the NHA feasibility study may not be fully carried into a future heritage area management plan completed by a local management entity. The purpose of theme development for the study is to determine that a viable theme structure exists in the study area. Careful consideration of themes and a public process for developing them during the study will assist local interests in later theme related planning if NHA designation results. Researching the broad array of stories and resources connected with them is also critical to the later development of potential NHA boundaries.

D. Step 4 - Natural and Cultural Resources Inventories, Integrity Determinations, and Affected Environment Data

1. to assist in assessing whether the region is a nationally distinctive landscape;

2. to assess whether there are resources important to the identified themes and if they retain integrity for interpretive purposes (criterion 5);

3. to determine if there are outstanding opportunities for conservation, recreation and education (criteria 3&4)

4. to ensure there is sufficient information about natural and cultural resources to describe the "Affected Environment" for the purposes of the Environmental Assessment.

Since the study being conducted is one investigating the feasibility of NHA designation, an exhaustive resource inventory may not be necessary for the second objective. Criterion 5 calls for the determination that resources important to the identified theme or themes of the area retain a degree of integrity capable of supporting interpretation. The study team should focus on identifying a strategic assemblage of natural and cultural resources that relates to the identified themes. It is these resources for which integrity assessments should be made. While many additional theme-related resources may be identified, the feasibility study needs to find only that there is a sufficient assemblage with integrity to provide a viable interpretive experience. The NPS and State Historic Preservation Offices, as well as state and local agencies and organizations, have inventories of cultural and natural resources that may assist greatly in the investigation.

In addition to natural and cultural resources, information necessary to assess outstanding opportunities for conservation, recreation and education (criteria 3&4) should include an analysis of existing public and publicly accessible private open space, recreation and heritage education resources, and whether there are potential opportunities to increase the level and quality of such resources through heritage area designation.

Additional information will need to be collected by the study team to enable the completion of an "Affected Environment" section for the Environmental Assessment. The study team should consult Director's Order 12 for guidance on undertaking the assessment. These should include at minimum, additional information on:

1. population and socio-economic conditions;

2. land use and transportation;

3. tourism, business and industry; and

4. air and water quality.

The affected environment section will also contain the necessary information enabling a determination that heritage area designation will be consistent with continued economic activity (criterion 8).

E. Step 5 - Management Alternatives And Preliminary Assessment of Impacts

At least two management alternatives should be analyzed. The first is the “no action/use of existing authorities alternative.” This alternative must be examined to meet NEPA requirements and assumes that there will not be any additional federal action in the study area other than through the use of existing authorities such as RTCA, L&WCF, NHL assistance, and other existing programs or services. It is the continuation of the status quo with references to any known changes that may occur including any state or local initiatives that may affect the region. A preliminary analysis of the positive and negative impacts of this alternative should be included in the impact section of the EA.

The second management alternative is NHA designation. The preliminary analysis of this alternative should include a description of the likely increases in funding and potentials for resource protection, interpretive programming and other positive or negative results of designation. The experiences of other NHAs may be used to comparatively illustrate potential results and impacts.

Depending on its feasibility, a third management alternative might describe the potential for local or state operation of a heritage area, independent of a federal NHA designation. In this alternative, there should be a description of likely funding sources and potential for resource protection, interpretive programming and other potential outcomes under state or local administration. An analysis of impacts should be included.

Additional alternatives may be explored as relevant to the study and region. These could include other types of heritage partnerships, trails, or other NPS assisted or unassisted endeavors. All management alternatives presented, of course, must be feasible to implement and their impacts described.

F. Step 6 - Boundary Delineations

It is important that the study team views the process of delineating boundary alternatives as being responsive to the research undertaken to develop potential themes in Step 3 and the resource based inquiry undertaken in Step 4. Boundary alternatives should be justified on the quantity and quality of resources that are integral to the interpretation of themes, community vision of the region's desired future, and opportunities for increased resource protection.

G. Step 7 - Heritage Area Administration and Financial Feasibility

A conceptual financial plan outlining the roles for all participants (criterion 6) should also be devised. The financial plan should demonstrate, at a minimum, the ability of the management entity to meet federal matching requirements that may become available upon NHA designation. The team should also assess capabilities of the management entity to leverage federal funding with other potential financial resources. It is recognized that the latter resources may not be able to be specifically identified during the study. What may be gauged is the past or potential capacity and creativity of the management entity to attract additional financial support. A five-year conceptual financial plan is suggested. The plan should, if possible, include estimates of funds to be made available by the management entity, state or local contributions, and potential funding by private interests (foundations, corporations and other organizations). The study team should be cognizant of any state sponsored assistance programs for heritage areas, regional projects and/or heritage tourism grants that may be investigated as potential funding sources.

NHA management entities often use a portion of their federal funding to make matching grants to local organizations. The portion of federal funds anticipated to be used for grants should be estimated, as well as any corresponding matching funds to be provided by grantees. A sample of a conceptual financial plan revenue chart is presented in Appendix 3.

Estimating expenditures for a potential NHA is not a necessary inclusion in a feasibility study. At this stage in the evolution of a heritage area, how funds will be specifically expended may not be known. Such figures are more appropriately contained in a heritage area management plan. If the potential management entity has developed preliminary expense projections they should, of course, be portrayed in the study.

H. Step 8 - Evaluation of Public Support and Commitments

Partnership commitments demonstrate, in large part, the capacity of the local participants to undertake and implement a future NHA. They may be agreements for working relationships, financial contributions, or pledges of other types of assistance. As in the case of the conceptual financial plan, specific commitments may be difficult to ascertain during the study. Indications of commitments to assist and work in partnership with the management entity by state and local governments and other organizations may be substituted for actual dollar or other specific contributions. The study team should, however, attempt to ascertain tangible commitments that partners are willing to contribute to the successful implementation of the heritage area. A sample way to portray commitments to the partnership is presented in Appendix 4.

IV. SAMPLE REPORT OUTLINE

The following outline is intended as an example to demonstrate how the various study steps may be integrated into a NHA feasibility study report and to analyze if a heritage area vision, mission and goals are attainable. Study teams will need to design their own report formats based on the level of information available and the manner which best portrays the viability of a potential NHA.

1. Executive Summary - The summary should include a concise description of the study, including a discussion on why the area has been judged to be nationally distinctive, and a conclusion as to whether the interim criteria for NHA designation have or have not been met. It should specify any supplemental steps to be taken that will permit any criterion to be met.
   
2. Chapter 1: Introduction - The introduction should include the following:

   • Purpose of the Study including reference to the authorizing legislation;
   • The Study Process including the methodologies used to develop the study scope;
   • Description of the Study Area;
   • Public Involvement Strategies;
   • Coordination With Concurrent Studies and Efforts including other NPS and state or local initiatives within the study area; and
   • Steps to Be Undertaken at the Conclusion of the Study including public review requirements, transmittal of the study to Congress by the Secretary of the Interior and the need for designating legislation.

3. Chapter 2: Study Area History and Contributions - The chapter should describe the events, people, places or other factors (including the results of any expert round table discussions) that result in the conclusion that the region is a nationally distinctive landscape that contributes substantially to our national heritage. The chapter utilizes information developed in Step 3.

4. Chapter 3: Themes - The chapter should describe the process for developing potential themes and discuss the selected themes and any associated sub-themes. The chapter utilizes information developed in Step 3.

5. Chapter 4: Affected Environment - The chapter should include information from the natural and cultural resources inventories and other data included in Step 4.

6. Chapter 5: Management Alternatives - This chapter sets forth NHA designation and other potential management alternatives including alternative boundary delineations. The chapter utilizes information developed in Steps 5 and 6.

7. Chapter 6: Application of Interim National Heritage Area Criteria - This chapter discusses each criterion and evaluates the potential for heritage area designation. The chapter draws upon the information set forth in previous chapters, particularly chapters 2, 3 and 4 with additional information developed in Study Steps 7 and 8 regarding the proposed management entity and evidence of public support and local commitments.

8. Chapter 7: Vision Statement - If a visioning process has been included in the study as a vehicle for public engagement, a suggested heritage area vision should be presented.

9. Chapter 8: Impact Assessment - This chapter describes the anticipated impacts related to the various management alternatives and any boundary alternatives that may be contained in the study. It should address potential impacts of identified alternatives, including "no action" on the elements described in Chapter 4 - Affected Environment.

10. Appendices - Appendices should include necessary consultation documents, and sources of positive and negative public comments. It may also include charts representing data gathered during the study, e.g., a matrix of NHL and National Register Sites with integrity ratings, lists of municipalities represented in boundary alternatives, literature or other references consulted, and other useful information to further inform the public.