Historic preservation consultation is not simply a compliance obligation — it is an integral component of successful project planning

Federal agencies are under constant pressure to deliver projects faster, spend taxpayer dollars wisely, and demonstrate results. A new report from the U.S. Government Accountability Office (GAO) argues they’re not doing enough strategic planning to accomplish those goals. While the report does not mention historic preservation by name, it reinforces something SHPOs have known for decades: good planning and early coordination lead to better outcomes.

The report reviews implementation of the Federal Agency Performance Act of 2024 (FAPA), which strengthened government-wide requirements for strategic planning, performance management, and stakeholder engagement. GAO found that the Office of Management and Budget (OMB) has not fully incorporated those requirements into its guidance, and several federal agencies have yet to fully implement them.

While the report focuses on government-wide performance management, its findings reinforce several principles that matter to State Historic Preservation Offices — and to the successful delivery of federal projects.

The Right Partners

One of GAO’s key findings is that OMB’s guidance does not fully reflect Congress’s direction to involve external stakeholders in agency strategic reviews. For agencies working on transportation, housing, energy, disaster recovery, and public lands, SHPOs are among those essential partners.

Apparently, “talk to your partners early” is now officially a GAO recommendation.

SHPOs bring decades of experience helping agencies identify issues early, navigate consultation efficiently, and develop practical solutions before problems become project delays. Strategic planning is stronger when those perspectives are included from the outset, not after decisions have already been made.

SHPOs Already Have the Data

FAPA also places greater emphasis on evidence based decision-making. Agencies are expected to use performance information to assess progress, identify risks, and improve outcomes.

SHPOs already collect information that can help agencies do exactly that — from consultation workload and review timelines to recurring project challenges and the effectiveness of statewide programmatic agreements and other streamlining tools. Incorporating this information into agency planning can help improve project delivery while ensuring compliance with the National Historic Preservation Act.

Preservation Isn’t the Bottleneck

Too often, historic preservation is viewed as a hurdle to clear rather than a planning tool. In reality, early consultation helps agencies identify potential issues before they become delays, reduce project risk, and develop workable solutions that keep projects moving.

That’s not just good preservation — it’s good project management.

Looking Ahead

GAO’s report reinforces a simple principle: agencies perform better when they plan ahead, use evidence, and engage the right partners early.

As the preservation community marks the 60th anniversary of the National Historic Preservation Act this fall, that message feels especially timely. For six decades, the NHPA has recognized that better outcomes come from early planning, informed decision-making, and meaningful consultation.

SHPOs have been helping federal agencies put those principles into practice for more than fifty years.

We hope agencies and OMB take GAO’s recommendations to heart.