Meeting Public Comments

William Owens [Iowa Child Advocacy Board]

This is the additional attachment letter from Sally Erny, Deputy Chief Executive Officer, National CASA supporting ICAB's position on this legislation.

Joe Artz [Association of Iowa Archaeologists ]

Honorable Representatives:My name is Joe Artz. As a professional archaeologist with 33 years experience as a consultant on historic preservation projects in Iowa, I oppose that part of HSB126 that would remove the State Historic Preservation Office (SHPO) from the State Historical Society (SHSI). The bill would move SHPO to Iowa Economic Development Authority (IEDA), while moving SHSI to the Division of Administrative Services. I am thoroughly familiar with the work done by SHPO staff, in partnership with SHSI. Separating the two would impair the efficiency and effective of both. SHPOs were established in every state by the National Historic Preservation Act of 1996 (NHPA). Section 106 of the NHPA charges SHPOs with reviewing federallyfunded, licensed, and permitted undertakings in their state that may, through ground disturbance or other development, affect historically significant buildings and sites. Currently Iowas SHPO reviewed 15002000 federal undertakings per year, consulting with and advising the agencies. SHPOs are also charged with administering the National Register of Historic Places program for the state; providing grants to local governments; maintaining an inventory of historic buildings, sites and structures, administering federal and state historic rehab tax credit programs; and providing educational and technical assistance on historic preservation issues. In many of these, Iowas SHPO staff is assisted by SHSI. Removal from SHSI would affect SHPOs ability to fulfill all its federallymandated duties. Because much of its workload comes from federal agencies, about 60% percent of Iowa SHPOs budget is funded by annual grants from the National Park Services historic preservation fund (HPF). The Iowa SHPO receives no direct appropriation from the state. The Study Bill before you states that the recommendations and decisions of the State Historic Preservation Officer shall be subject to the review and approval of the Director of the Economic Development Authority. This could put the IEDA in direct conflict with the Section 106 process, in which the SHPO only advises the agency. The final decision is made by the federal agency, not SHPO, and not the director of the state agency in which SHPO resides. To summarize, Iowas State Historic Preservation Office serves a role defined by Federal law, with its activities defined by the implementing federal regulations. That role is fundamentally advisory and administrative, not developmental. Conflict between IEDA and federal agencies would complicate and risk delays in federal funding to projects benefiting the state. It is imperative that HSB126 not impair SHPOs ability to carry out its primary duties, which devolve from federal, not state, legislation. The best way to ensure that would be to amend the bill to keep SHPO within the State Historical Society as part of DAS. SHPOs role can be viewed as administering the states compliance with federal legislation. Its role is advisory, not developmental. Its responsibilities correspond more closely with that of the Historical Society and DAS than with than IEDA. I urge that HSB126 be amended to keep SHPO within the State Historical Society as part of DAS. Thank you for consideration of my comments.