 Good afternoon. I'm Sherry Freer, and it's a pleasure to be with you this afternoon. I'm joined this afternoon by my colleagues Paul Lucignan, Julie Ernstein, and Lisa Davidson. The National Register has relaunched its effort to update the TCP bulletin, last issued in 1998. I have a 30-minute presentation to share with you on questions raised about national register practice and TCPs over the past two decades and how we have hopefully answered them in the draft TCP bulletin issued for comment as of October 27 of this year. As we move through this presentation, I'll refer to the original bulletin as just that, the original bulletin, and to the recently released version as the draft bulletin. In closing, I'll provide an update on the National Register and National Historic Landmarks initiatives that I introduced last year at the Pass Forward Conference, and these were initiatives to enhance the diversity of national register listings and NHL designations. The title of this presentation comes from Dolores Hayden's 1997 book, The Power of Place. It was my encounter with her book that gave me the words to express what I long thought was true, that seemingly ordinary places that hold public memory remain unacknowledged for many cultural, ethnic, and identity communities. Back in the 90s, when I was studying historic preservation and landscape architecture, we called those places vernacular buildings and cultural landscapes. Today we might call them traditional cultural places. Here's the agenda for this session. First, to set the context for this presentation, I'll do a quick run-through of national register practice. Next, I'll review the history of the development of the original bulletin and its revisions in the late 90s. Then I'll present some of the issues that have been raised in the decades since about potentially national register-eligible TCPs, along with an analysis of the changes from the original bulletin to the draft bulletin that address those issues. Finally, I'll lay out the path to revision and reissuance of the TCP bulletin, and along the way there will be a few pop quizzes. The National Historic Preservation Act of 1966 authorized the Secretary of the Interior to expand and maintain a national register of historic places of buildings, structures, objects, sites, and districts, significant in American history, architecture, archaeology, engineering, and culture. Listing in the national register brings recognition, as well as potential financial benefits, but listing doesn't guarantee that a place won't be altered or demolished. To be listed in the national register, the resource under consideration must be an actual place or object, it must possess historic significance under one or more national register criteria, and it must retain the integrity to convey that significance, although not all seven aspects need be present. Here are a few national register-listed TCPs that are representative of the different property types. Bohemian Hall Park is listed as a building, Horn Mound as a structure, Sleeping Buffalo Rock as an object, Takatia Peak as a site, and Tarpet Springs Greek Town Historic District as of course a district. To assist in the preparation of nominations, the National Register has issued guidance, most often in the form of bulletins. You'll find most of these bulletins along with other guidance on our website at the link shown and to be pasted in the chat. Here you see examples of guidance for specialized property types, such as post offices, which are of course buildings, ships, which are structures, and rural landscapes, which may be sites or districts. And here you see examples of bulletins issued to provide guidance for applying national register criteria. Bulletin 15 is foundational for evaluating and documenting any potentially national register-eligible place, providing guidance for all criteria and criteria considerations. Bulletins 22 and 32 provide further guidance for criterion B, places associated with significant persons, and criterion consideration G, places associated with the recent past. Several bulletins focus on unique places, such as residential suburbs, mining properties, and yes, traditional properties. The original TCP bulletin was published in 1990 in response to the amendments to the National Historic Preservation Act. Those amendments focused on preserving and conserving elements of cultural heritage. The bulletin was revised and reissued in 1992 and again in 1998 to address questions about religious places, property types, and significance. And now it's time for our first pop quiz. A traditional cultural place at TCP is a national register property type. Is the statement true or false or are you not sure? And I believe we have about 20 seconds to answer and correlate the responses. I have set a timer for myself, so I will be sure to keep track of that and move on as appropriate. And according to the poll, 70% say false, 20% say true. And the answer is false. A TCP is not a national register property type. The TCP you see here is LaWaite LaLa in English, Mount St. Helens, and it is listed in the National Register as a site. Oh, and it appears that 10% are not sure. A TCP may be classified as a building, structure, object, site, or district. For consideration for listing in the National Register, like any place, a TCP is evaluated according to national register criteria for significance and integrity. Places of traditional cultural significance have been listed in the National Register since 1969 with a designation of medicine wheel, medicine mountain as a national historic landmark. In 2011, the National Park Service began work to update the TCP bulletin, but in 2017, the work was placed on hold. In 2021, the NPS resumed this work and with the release of the draft bulletin, on October 27, the reissuance process has restarted. In the decades since the original bulletin was last revised, many questions have been asked about nominating TCPs to the National Register and the recently released draft bulletin attempts to address theirs. In the next series of slides, we'll compare language from the original bulletin to the draft bulletin for a few of the most commonly asked questions. What is a traditional cultural place? There is no change from the original bulletin to the draft bulletin and how a traditional cultural place is defined as applies to potential national register eligibility. A traditional cultural place is a building, structure, object, site, or district that may be eligible for inclusion in the National Register for its significance to a living community because of its association with cultural beliefs, customs, or practices that are rooted in the community's history and that are important in maintaining the community's cultural identity. The draft bulletin expands on this definition by providing a list of the essential characteristics of a potentially national register eligible TCP. One, a place must be associated with and valued by a living community. Two, that community must have existed historically and continue to exist in the present. Three, the community must share beliefs, customs, or practices that are rooted in its history and held in the present. Four, those share beliefs, customs, or practices must be important in continuing the community's cultural identity and values. Five, the community must have passed down the shared beliefs, customs, or practices. Six, the shared beliefs, customs, or practices must be associated with a tangible place. And seven, to be listed in the National Register, a place must meet National Register criteria. It must have significance. That is, it must be important in the community's history, architecture, archaeology, engineering, or culture. And it must have integrity. That is, it must retain the ability to convey its significance. Before we continue, it's time for another pop quiz. Only Native American places can be included in the National Register STCPs. Is this statement true or false, or are you unsure? And we'll take about 30 seconds for voting and to, uh, tabulate those votes. And this statement is false. 97% of you said this is false. 2% were not sure. Well done. Here you see the Green River Drift Trail in Wyoming. It was listed in 2013 as a district. This 58-mile-long corridor played a significant role in the development of the ranches in the Upper Green River Valley. Remember, ranchers still use the main trail and its spurs to move cattle. Like people the world over, Americans of any cultural or ethnic background may have places to which they attribute traditional cultural significance. And those places that meet the National Register criteria may be nominated for listing or recognized as eligible for listing in the National Register. Another question frequently asked over the years has been, how is the period of significance determined? As in the original bulletin, the draft bulletin provides two different kinds of periods for a National Register nomination. The period of significance may be the period of time in which the place gained significance according to the beliefs of the community that values it. Or the period of significance may be for the period of time during which the place has actually been used for cultural purposes. Again, the passage of time since the original bulletin was issued has allowed for the inclusion in the draft bulletin of many listings to provide examples for guidance. On the left is a listed TCP with a period of significance determined by when the place gained its significance according to the beliefs of the community that values it. In the traditions of the several tribes that value Goldstrait Canyon, Sugarloaf Mountain, creation to the present is the period over which they conducted traditional cultural practices at numerous and specific locations here. On the right is a TCP with a period of significance determined by the period over which the place has actually been used for cultural purposes. Pasquale Plaza has served as the location for ceremonial activities of the UMA community since Pasquale Village was founded in 1921. The period of significance then is 1921 to the present. Comment to both these TCP's and indeed to many TCP's is the fact that the period of significance extends to the present. We call the definition of a TCP it is a place that may be eligible for inclusion in the national register for its significance to a living community because of its association with cultural beliefs, customs or practices that are important in maintaining the community's cultural identity. So it follows that if a place is important in the continuity of a community's cultural identity the period of significance continues into the present. But that idea of continuity has raised questions over the years. So let's consider this issue. To be eligible for inclusion in the national register as a TCP a place must have been in continual use by the traditional community that values it. Is this statement true or false or are you not sure? I'm going to take another 30 seconds to tabulate the responses. And the responses are 44% say it's true, 37% say false and 16% say not sure. The statement is false. The Senyo Ancestral Origin landscape in California was listed in 2014 as a district with a period of significance of creation to the present. It's recognized by the indigenous people of the area as the place of creation and the period of use for traditional purposes extends back to this time even though the people that value the place were forcibly removed from it. Although they did not have access to it in contemporary times they maintain their cultural traditions associated with the area even as it was taken over by other governments and privatized. A place may indeed be important in the continuity of a community's cultural identity despite the community's inability to access the place for some period of time. Here you see the Akmulgi Old Fields in Georgia determined eligible for listing in 1997 for its cultural and historical significance to the Muskogee Nation. The Muskogee had no choice but to physically abandon the area upon their forced relocation by the federal government in the early 19th century but they never forgot this place. They revered it as their ancestral homeland and it is as significant now as it was then to the Muskogee cultural identity. Questions have been asked about how to resolve conflicts between historical and contemporary sources about the significance of a place. In documenting any place be it a site significant for its role in cultural identity or how significant for its architecture a nomination preparer may encounter conflicts between historical and contemporary accounts between what is documented in books and what the community shares about it. Both the original and drap bulletin stress the traditional knowledge is an independent line of evidence provided by the people who are the authorities in their culture and the connection that culture has to a place. However this is not to say that thorough thoughtful research and documentation is irrelevant in preparing a nomination. Recall that national register regulations require that a nomination be adequately documented and professionally and technically correct and sufficient and that remains true whether the place is a TCP or an architectural gem. In these passages the same example provided in both the original and drap bulletin demonstrates the important connection between traditional history traditional associations and a traditional cultural place. The specific example is included in the draft bulletin. This image shows Spirit Mountain in Nevada a site associated with the creation stories of several tribes. The mountain continues to serve an essential role in their traditional cultural practices and beliefs. Tribal members shared information on the significance of this place with the understanding that they could not provide detail information because of its extreme spiritual sensitivity. Nevertheless the nomination is well documented with both historical and contemporary sources including oral histories. Over the years many questions have been raised about how to assess a place's integrity. The original bulletin's use of the phrase integrity of relationship has been misunderstood as adding an eighth aspect of integrity to the seven existing aspects of location, setting, design, materials, workmanship, feeling and association. In the draft bulletin integrity of relationship has been reframed as is the relationship essential? The same question could have been asked as is the relationship integral but using this closely related I word risks the same confusion. Likewise integrity of condition has been restated as does the relationship endure to provide guidance in assessing whether a traditional community's relationship with the place endures despite changes to the place. And now for our final pop quiz. This is an image of a national registered listed TCP. Is this statement true or false or are you unsure? And we'll again take another 30 or so seconds for you to answer the question and for us to correlate the results. As you think about your answer consider this photo from 1976. This statement is true. The Creek Council tree site in Oklahoma was listed in 1976 as a site for its historical and cultural significance to the Muskogee Nation. Members of the tribe arrived in the vicinity in 1836 after their forced relocation from their homeland in the southeast by the federal government. They chose the site of this magnificent oak as the gathering place for travel business ceremonies, feasts and games. Despite the visual intrusion of modern development the place continues to be significant to the Muskogee Nation whose members hold an annual celebration here. The results of the poll 48% say true 50% say not sure. And many thanks to Felicity Good, historic preservation planner in the Tulsa Oklahoma Planning Office for this recent image. And again the passage of time since the original bulletin was issued has allowed for the inclusion in the draft bulletin of many more examples of national registered TCPs addressing the issue of integrity. On the left is Cave Rock in Nevada listed in the national register in 2017. It continues to be regarded as a sacred place of extraordinary spiritual power to the Washoe people despite the intrusions of a double-bore vehicle tunnel and for a time recreational rock climbing. On the right we again see La Waite Lotla Mount St. Helens listed in 2013. It continues to be a place of traditional activities despite the dramatic change in its appearance created by the enormous creator from the 1980 eruption. Let's take a look now at the proposed path to the reissuance of the bulletin. We've developed a 15-month schedule aiming for issuance by December 2023. The schedule assumes six months to conduct partner and public outreach and government-to-government consultation with Native American tribes, Native Hawaiian organizations, and Alaska Native corporations. The draft bulletin can be downloaded from the NPS Planning, Environment, and Public Comment website at the link shown here and pasted into the chat. This site is also where we'll be posting the consultation and outreach schedule. We anticipate conducting those sessions via Zoom and we'll be posting information here later this month. Comments may be made on the bulletin via this site or by email to the address shown here. You may also mail comments to us in Washington DC. Before I end this presentation I'd like to update you all on the initiatives I introduced at last year's Pass Forward Conference. In March the National Register Program began evaluating older listings to identify potential areas of significance related to cultural, ethnic, and identity groups. As discussed at last year's conference the area significance categories had evolved and expanded in the decades since the National Register was formally established in 1966. Project's goal is to identify potential additional areas of significance for older listings and to work with partners and the public to update those nominations. We anticipate publishing the results of this work in 2023. This year has seen the release of several guidance documents. The NHL program has released theme studies on labor history and Cold War history. Remember that NHL theme studies can provide context for national register nominations not only at the national level of significance but at the local and state levels as well. These and other recent recent theme studies are available at the NHL website at the link shown here and pasted into the chat. In September the National Register program released the inaugural issue of the best practices review to provide guidance on frequently raised questions about national register practice. The first issue addresses evaluating non-historic exteriors. Future issues will be released quarterly. We'll address counting structures in historic districts, developing additional documentation for existing listings, and using oral history in nominations. Over the past year we've been building a new sample nominations page featuring more than 100 nominations on a variety of topics. We anticipate this page going live later this month although it will always be a work in progress as we add new listings. And with that I'll conclude this presentation. Thank you for your kind attention. Paul, Julie, Lisa, and I look forward to your questions and comments. There were some really good questions in chat and one of them was the first one is when we often get you know will the audience be able to access the slides and someone from the trust had noted that presentations will be shared out with conference attendees and we'd also like to note that past presentations for the last couple of years are also posted on the National Register website so you'll be able to catch up with this one or if you happen to miss last year or the years before you can catch it. And then there was a question and I'll just read it from the chat. I'm wondering about the relationship between the TCP category and the larger prohibition on listing of churches and religious properties. Obviously many TCPs have spiritual significance, spiritual significance, and then the question continues are historically black churches for example eligible under TCPs even while the National Register discourages church listings at large. I know there's a lot in there. I would say generally the prohibition against religious properties is always something to take into consideration but the revisions to the National Historic Preservation Act that I referenced earlier in our TCP guides as well don't cast traditional spiritually used places as religious properties per se. And with that I'm going to turn it over to Paul for a better answer because he has dealt with this many many times. Paula Signan is our senior historian. Many of the states for which he does reviews are on the west coast and have been many locations, many places that have spiritual significance to Native American tribes. Right, thank you Sherry. In terms of Native American and those types of folks we basically said that if you look at their cultures look at from their perspective while we as an Eastern you know as Westerners I may say that's religion to them it's it's part and parcel of who they are is their culture is their identity and so we don't treat those as quote religious properties we say they're spiritual properties they have cultural significance and so that the ramifications of religion that involve the criteria considerations really are not all that applicable in most cases for for those kind of TCP's but that also applies to non-native American ones as well. Black churches are part of the cultural entity of the black communities they're not simply places of religion they're places of social and cultural importance and when nominations emphasize those aspects of a significance then they clearly would need the criteria considerations. So criteria consideration really was developed early on to prevent nominations that were simply based upon a religious group so that you wouldn't come by and say oh this is a Catholic church therefore it's eligible for the national register that there was that kind of separation between the religious aspect and the significance of that. As we've evolved in those we were looking at churches in particular and oftentimes with minority communities as much more than just the religious aspects to them that's an important aspect but there are also cultural and traditional associations and therefore I mean TCP's black churches in particular this question can easily be documented as TCP's if again there's a continuing community associated with them and one of the examples I believe in the slideshow was of a church and cemetery collection in Louisiana that was associated with Creole of color and for them the church was a central point of social and cultural interaction as well as religious interaction and it was keenly important for maintaining their cultural group down there and so it was listed as a TCP. I was just dropping something in the chat to have moved over excuse me could we take a quick second and just do introductions because folks had asked who's who and I thought our names were all on the screen but that may be that may not be the case. Yes thank you I am Sherry Freer I am Chief of the National Register of Historic Places and the National Historic Landmarks Program. I've been in this role for about two and a half years now I'll toss it over to Paul. My name is Paul LeSicken I'm a historian with the National Register of Historic Places Program I've been with the Park Service for about 30 years now and as Sherry mentioned most of the states that I deal with are western states. I do have some East Coast states but mostly western states which means I've been exposed to a lot of TCP's particularly Native American TCP's and therefore I have this kind of back knowledge of TCP's even though I'm not an anthropologist or an ethnographer. I'm Julie Ernstein and I'm a former archaeologist with the National Register and the National Historic Landmark Program so Paul and I and I have not been there for 30 years by any stretch I had done many reviews together so I didn't want to get a jump on people's questions but we do have some really exciting examples of you know carving a space in these nominations and demonstrating a lot of flexibility with the criteria and I've just recently moved on to another program but I'm joining the team back here today to have this important conversation. I'm Lisa Davidson I'm Program Manager for National Historic Landmarks and I'm here partially to listen to my more expert colleagues talk about traditional cultural places and be available for any National Historic Landmarks questions. I see one quick question that's easy to answer in the chat and it's basically confirming whether buildings that are within TCP's are eligible for the historic tax credits just as any other national register listed property. Yes the only qualification for the historic tax rate is to be a country is to be listed in the National Register of Historic Places as a contributing resource to a district or as an individually eligible resource so if it's again the question would be is that specific building contribute to the TCP so if it's like the the Greek town in Florida if it contributes to the significance of the Greek town TCP it would qualify for the tax credits if on the other hand it's a Native American TCP in which the building is an intrusion or a non contributing resource then it would not qualify for the tax credits. And another audience member had asked if the draft TCP bulletin is available and I had typed the address in so it could be shared but that that document is currently available for public comment so we and there was a very long complicated URL so we absolutely would very much appreciate people's comments on that. And I'm seeing that there is a question about whether different regulatory approaches or regarding are there different regulatory approaches taken the TCP's recognizing that the continuing use of the site is integral to its value that is I will say that is outside our lane and I'm sorry to be unhelpful on that. The advisory council for historic reservation is the federal agency that is responsible for participating in 106 consultations they don't always participate but that's the word I'll use as opposed to well I could say oversight of the 106 process the federal regulatory process whereby agencies do have to take into account their the effects of their undertakings on any national register listed or national register eligibility property. They would certainly be the best people to contact and we will look for a link for that and we'll drop it into the chat. What the question does highlight though is the importance in national registered documentation of outlining those aspects you know what are the carry I mean it's important in describing the TCP to describe what the character defining aspects of that might be for architectural buildings those are clear characteristics. For TCP's it may be things such as the flora and fauna that may be associated with the site the lack of auditory issues and other things so that you you outline those such that they become much more important or useful management tools when someone then goes to the national register for eligible resources and decides how best to manage or mitigate issues. If it's not in the nomination then they might be missing out something and someone's perspective on why the property is significant may differ from the traditional community's perspective on that. Yeah and there's a question here that I'll I'll tackle because it's got criterion D can it can a TCP be eligible under criterion D due to the significance of information that it has to the community rather than archaeological information as judged by archaeologists for example a place connected with stories or teaching within and it probably goes on to continue within the cultural tradition and there were two really great recent examples of this. One is a multi-property submission that came from Washington state called the spiritually significant rock features of the southern columbian plateau and okanagan highlands in Washington state. The authorship that was written by the senior archaeologist with the Confederated Tribes of the Coalville Reservation and their archaeology program it employed a it ticked all the boxes and we were really happy to see it. The chronology employed a traveling focused chronology that built upon but went in a slightly I'd say augmented direction from sort of the standard regional chronology. The significance this cover document it absolutely noted from the outset that from the tribal perspective it is the traditional cultural significance of these rock features that occupies primary significance. It kind of reframed and departed from a standard archaeological notion of typology while still meeting the requirements of outlining registration requirements within a multi-property submission and then probably more to your point it's approach to research questions that that information potential it claimed that it claimed ethnographic space as the appropriate methodology for investigation and there are other really great examples. A ballast island which was another nomination that just absolutely made abundantly clear that it was information from this site that was of significance to the tribe that trumped sort of standard archaeological information and included in those research questions questions that would be garnered via oral history ethnographic information and methods well beyond simply excavation. I see a question that asks about national register criteria asking whether we would advise or whether a TCP analysis would be used as a catch-all to gain designation for places that would not meet national register criteria A, B, C or D. All properties listed in the national register were proposed for listing in the national register do need to meet one criterion at least one. Most often we see TCPs come in under a criterion A. A can be a history or pattern of history which also encompasses cultural activities. Cultural activities are part of a traditional community's history so the TCP is not a workaround and it's not a catch-all as anything nominated to the national register needs to meet the criteria for evaluation which means significance and integrity. Yeah and and that that question raised a really interesting point that's worth emphasizing we we don't at the park service or our counterparts in state offices and other federal agencies we don't tell people that they have a TCP they tell us that this place is significant to them as a TCP and and I think that probably tied into a question that we're seeing are there standards what's it moved are there standards for what the NPS considers to be a people or a culture and you know a community comes to us and tells us about about their history whether it's you know they are members of a a particular neighborhood a particular congregation a particular tribal entity so that that information you know comes from those folks in their history. Just want to point out for my colleagues there are a few variations of the question about discussing integrity a bit more in the chat I think you covered this sherry but I think it may be be worth reiterating some of those points a little bit about how integrity is is handled a little bit differently for a TCP. Integrity is the ability of a place to convey its significance now what that looks like I'm sorry to say depends but it does very much depend on how the community perceives that place whether the community can look at that place and recognize it for its significance in one of our bulletins we say one test for a building is say a 19th century building is what a contemporary walking down the street a 19th century contemporary walking down the street recognize that building now that again is not to say that any building needs to be a pristine and encapsulated perfect having perfectly transitioned into the 21st century modifications happen and those are always acceptable and to some extent but integrity is is whether particularly for TCP is whether it will be recognized by the people that value the place what are they looking for what do they value in that place what about that place says to them this is a place of cultural significance to us yeah integrity has always been based upon the significance of the resource and so again the importance of a nomination documenting what about this resource what either physical features or associative features are significant to the tribal community or to the traditional community then assessing the integrity of those factors and such that again if it's a space that has that has no buildings on it then expecting materials or design to be aspects of integrity really are not going to have a lot of relevance as much as the associations of feeling and association and location and setting and so we would look to the nomination to highlight what are the important aspects of integrity and then to convey how those are still intact from largely again from the the traditional community's perspective it's not purely and simply that aspect there still has to be some assessment of physical integrity but the the role of the different aspects of integrity change depending on the resource and again that's true for all sorts of property types particularly for TCP's and I hope I think that's expressed in the bulletin and the draft bulletin because it's one of the factors that has come up a lot in terms of of who gets to say it has integrity or doesn't have integrity and what's the appropriate approach to do that yeah one of the audience members observes an idea developed within tribal meetings in north and south dakota is this notion of a national register criterion e that for resources that possess attributes and elements considered significant to indigenous groups representations of cultural life ways beliefs ceremonial activities customs genesis or creation astronomers artistic forms technologies or spirituality to include relationships to the universe in accordance with NHPA section 101d6 or 54 USC 302 706 and that's certainly an interesting point we would I think answer that we we have currently listings that speak to many of of these things attributes and elements that are representative of life ways beliefs many different sorts of ceremonial activities certainly origin you know genesis or creation activities for instance the the spiritually significant rock features is just one example that I cited earlier there there is a a being known as rock who brought to people the notion of time immemorial so that's that is a frequent detail that that comes up certainly astronomy's solstice and different sort of calendrical markings artistic forms technology spirituality um so the the notion of needing to add another criteria where in many instances the existing criteria have have created space for these sorts of activities and historical events and that's that's where I think too the the samples in the nominate in the the draft bulletin will kind of highlight some of those um again it's very difficult for us to provide samples of tcp nominations because a lot of them do consent contain sensitive information but what we can present about those um do show aspects of all of these kind of features and factors that really I think broaden the scope of what people think of in terms of properties eligible and listed in the national register um and and and you know that that that has been topic discussed in terms of the the the fifth criteria and in cooperation of it but again Julie we found that all of those kind of aspects can be um placed into and under the current criteria and here's an interesting sensory question has sound or smell whoops the question jumped um has sound or smell ever been and I'll find it again but um has sound or smell ever been emphasized as a a a means for or an attribute of significance for a tcp rather than what is visually apparent I would say yes to the lack of sound um when places are associated with vision questing or ceremonial activities in which seclusion or lack of distractions are important then the lack of sound is a character defining element of the resource perhaps um I'm I'm not aware of any in which sound has been an active component of it but I'm sure a case could be made for that as well I mean the sound of rushing water um associate with you know I mean like again you know there may well be um smell I don't think I've come across yeah it's interesting and we have a question about what about an urban historic district that was inhabited by one immigrant group more than 50 years ago but they have moved out and the area is now inhabited by another immigrant group for less than 30 years the buildings are modified can the district be a tcp to the first group that lived there potentially I was thinking of your modified casitas I don't know if that would fit the bill yeah I mean it it's possible I mean again it's tcp is not necessarily continued use so that the the original minority community doesn't have to still live there but their associations to that their value of that community as part of their cultural identity would would be important to document and that may or may not be the case um I think you know again it may have to do with reasons of why they left the area why they moved on um but I don't think you could just make a an automatic statement that because a group traditionally lived here it's a tcp the whole concept of a tcp for eligibility in national retro is because to a current day traditional community they still value and have a belief so practices associated with that community that may be the case but on the other hand it could also be that it's not a tcp it might be eligible under criterion a for its historic significance as association with particular community um those kind of things you have to balance and look at when you're looking at those kind of places um there's an interesting question that poses um on integrity if a pre-contact tcp has been destroyed by white settlement beyond just being denied access to the place does that eliminate a location from listing and um I'm thinking of for instance ballast island in seattle that has been infilled it's still there it is simply um uh filled over by layers and layers and layers of of rock so it is it is physically inaccessible um but still is used and visited actively for um you know for teaching as a location of uh important transfer of uh intergenerational information uh among a number of groups um in and around uh elliott bay and puget sound um and on that issue of integrity just uh following up on a question that I see here that if integrity depends on whether a member of the community can sense the significance of the place how do the reviewers of the national register nominations have a role in confirming whether that exists if they are not a member of the community and that comes back to what paul was describing earlier uh with with respect to documentation and the nomination simply tell us simply explain it's gone out uh so help us understand we are not in the business of uh saying no to nominations we like to list properties but we do have that responsibility to ensure that they are adequately documented and it didn't even be a huge lift um we talked last year about uh documentation arms race where nominations are getting longer and longer and that's not necessarily necessary use that word twice to um to adequately document a place it could be 10 pages it could be 20 could be 30 I do recommend that they be more than the earliest nominations where we were seeing one two three page nominations so documentation explaining why a place is important explaining why it's significant is important and there's a question that says if a place were listed before 1998 on the national register can it be amended instead of having to totally reapply under new tcp or other guidelines as to integrity or significance in the community and I would say any any nomination where new information and scholarship be it ethnographic scholarship oral history scholarship folklore scholarship scholarship in any discipline that that yields new information about additional significance that that would be an entirely appropriate uh reason uh to prepare additional documentation for that whether it's you know a site a district whatever form uh it assumes and if no one wants to does anyone want to help I want to follow up on the uh the question about um access being issued because of ownership uh I would say that you simply do the very best you can and I appreciate that challenge uh Paul I'm sure you've encountered this in the in the course of your career yeah yeah there are there are some cases in which you have to do the best you can you know okay you may not be able to physically step on the site are there um aerial photographs of the site for which you can other google earth you know what is what can you see from other places other advantages to this resource so that you can cite what's there what's not there level of alterations level of integrity um and I would say too with respect to the significance of a site this is where I think for traditional cultural places oral histories are particularly important um much of uh many times the significance is not written down by a community it's passed on through an oral tradition oral histories will play uh as as legitimate a role in documentation as do maps you know journal articles and books and and is the party denying access to the site the owner of the site um because that might or might not be the case but also just bearing in mind um you know the the sort of inconvenient truth that if that is the owner denying access the owner may or may not be in favor of the listing of that site so when the documentation is prepared um it may well result in a determination of eligibility as opposed to a listing in the national register but both certainly afford the same consideration in the section 106 lane and then perhaps in this hypothetical scenario at a future date a a new owner may be in favor of listing at which point it could move to listing I mean those those situations arise as well and before we get our two-minute warning on our session I do want to say I so appreciate the conversations the comments and the questions that are going on here in the chat all of this will be incredibly helpful and meaningful in our continued efforts to revise the TC people and make sure that what we've written is addressing some of these these issues these comments and questions because if it's not clear it's not going to be helpful and there will always be room for more examples and I'm seeing some some really thoughtful comments about what we might include in terms of examples so I thank you all for that there is a question that says has um the tcp concept been used to list african-american communities that have been continually occupied by the same families but the buildings are modified and lack the usual level of integrity for a historic district let me just say as a threshold response that integrity really has a great deal of flexibility there are those seven aspects buildings can be modified if you take a look at bulletin there is one example that I did include not a tcp but such a good example of how modification can happen we hear a lot of talk and concern about new facades or not facades but finishes a form stone room siding on buildings those are not dealbreakers in terms of integrity so I would say the same is true for a property that may be thought of as a tcp there is flexibility there again it's important to explain in the nomination why the place is significant and why it has integrity how it conveys its significance through what you're seeing and I see we have our time out notice and it's time for us to wrap this up so I thank you all for participating again fantastic comments and questions I think Julie Paul Lisa and I think our tremendous team at the National Trust for the support in doing this presentation thank you all take care thanks everybody