Can those with experience in this area advise on the benefits and disadvantages of nominating a locomotive to the National Register of Historic Places?

I have a good grasp of the history of the specific locomotive and others of the same design and have prepared a number of grant requests to fund its restoration. I've looked at the NPS materials on nominations and have a good example of an approved nomination and believe I can put together a credible case for listing, including a case for local, regional, national, and international historical significance of the locomotive class and local and regional historical significance of the specific locomotive.

The locomotive is owned by a non-profit and is being restored for operation. It is currently undergoing restoration and overhaul in a leased shop and is not part of a larger collection of rail equipment. A long-term goal when it becomes operational is for it to be housed in a maintenance shop with an integral interpretive area.

I searched for other threads on listing locomotives and rolling stock on the National Register, but none that I found addressed the potential gains or losses of a listing. We made an initial, informal contact with the State Preservation Officer several months ago.

Before investing a lot of time and effort, I'd like to hear from the rail preservation community. Is it worth the effort? And why or why not?

Getting listed on the NR on its own doesn't cause money to suddenly rain down on your project. But it is a tool to add leverage to future grant applications and perhaps open doors to new opportunities you didn't have before such as Certified Local Government grants (if you're within a CLG area that is). Certainly once you get listed, play it up as much as possible with press releases or a media event.

Let me preface this by stating that I have an academic background in historic preservation, and professional background in both preservation and museums (including railroad). I've also successfully written a National Register nomination which was approved by the SHPO and the National Park Service (for a building, but the form is the same).

When I was in graduate school (not all that long ago long ago), I worked for over a year as a paid student assistant in a State Historic Preservation Office, working on a number of different things, including working with NR nominations.

From my perspective, there are many advantages and also misconceptions about doing a NR nomination an then being listed on the Register. Some of the basics are nicely summarized on some SHPO websites....Maine's is pretty good: http://www.maine.gov/mhpc/national_register/index.html

The NR is basically a detailed survey of historic resources across the country. Not every old farmhouse can be nominated, because they need to meet at least one of the four specified criteria, but most historic railway equipment does that because it's "last of its kind," "last from its builder," etc. etc. Not every piece will have national or international level significance, but that doesn't mean it is less important or will not be considered. Indeed, the majority of items listed on the NR are only noted as "significant" at the local or state (regional) level.

Listing on the NR does not prevent anything from happening. You can make all the changes you want. You can restore it to operation. You can paint it pink. You can scrap it all together. You future plans can change and the NR will not restrict you from doing what you want. The nomination is more of a detailed snapshot of a historic resource at a moment in time. Documentation is key and modern NR nominations are fairly detailed. If you look through older nominations from the early days of the NR in the 60s and 70s, often one or two pages total is sufficient - no longer. The museum I work for is listed on the NR (done in 1983), including both the historic line and the equipment collection, and our nomination is still fairly short.

Being listed on the NR brings both credibility and bragging rights. The NR nominations are administered at the state level by your SHPO, but the register is maintained by the National Park Service/Dept. of the Interior in Washington. I regularly use the following line (or some version of it) to help promote my museum: "The museum is recognized by the National Park Service as the oldest continuously-operating suburban trolley line in the United States, and is a registered historic district." Records are kept in Washington, and Washington has to sign off that your resource is deemed as significant and historic. There's some weight to that. There's also the value to the town and local level to have another "historic site or district" in their community. Because the NR nomination is both technical and detailed, it is a credible certification. You can't just write and approve a NR nomination overnight (take note of this - it's not a drawback but may be a hurdle for some organizations). Grantors may also take note of you being listed on he National Register and it just may be the feather in the cap needed to get more funding. Some preservation grants require listing on the NR to even be considered.

I'm glad to hear you have already made contact with your state's State Historic Preservation Officer. Most offices have a National Register or Survey specialist who works more closely with nominations and guides them through the drafting, approval, and submittal process. They are great resources, because they know what the Park Service is looking for in terms of wording, documentation, etc. Keep in mind that railroad equipment is a bit different from buildings and structures, which is 95% of what they probably deal with. They probably know that railroad equipment is different too, but may not know just how, so some education on your part may be necessary. I'd recommend if you elect to pursue it that you invite them for a site visit to show them what you'd like to nominate and explain a little of the background. Don't overwhelm them with rivet counts, but having them see it and understand some of the history will help them better understand your text when you submit a draft. You will likely have to submit more than one to the SHPO to refine your text and make sure everything meets NPS guidelines. Be ready for that and keep communication open.

Besides the text, the more complicated part of the nomination may be the photo submittal process. These are archival quality documents, so there are very specific guidelines for photographs. In the old days, B&W photographs with negatives were sufficient. With digital, there are more restrictions about file names, image types (.tiff only, I think) etc. etc. You also will need to list and map the location of the resource using UTM coordinates. The SHPO's nomination person will be able to assist or recommend a good resource for using this generally unfamiliar coordinate system.

It's a commitment of time, and you need a decent writer to get the narration sufficient. Average Joes' submit NR nominations, as do paid professional consultants. It's not beyond most organization's reach.

In my opinion, railroad equipment as a whole is under-represented in the National Register, so it's great to see you interested to pursue it. It's a great body of work, public in nature, which documents historic resources across the country and railroad equipment can be carefully documented in this way to add to "our historical story."

Having an example of a successful railroad equipment nomination is great, and you mentioned you have one. You can always ask your SHPO to provide copies of any other railroad equipment ones from other places in your state. I have one or two myself for steam equipment I'd be happy to share with you if you like. You can also write to another state's SHPO to request a copy of a specific nomination if you know another one was done on another locomotive of the same wheel arrangement but different railroad, for example. SHPO's are typically overloaded state agencies, so turnaround is not always instant, but 90% of the people I've encountered in their offices are passionate about the work they do to try to document, preserve, and protect the environment they work in.

Long winded, I know, but I hope this is helpful. Feel free to PM me or send an email to info@shorelinetrolley.org if you have more questions.

Great write up ---

If memory serves me right, there are very few entries on the register that "move."

The one thing being listed "buys you" that is worth real dollars comes from the fact Federal money can't be used to tear down an entry, say for example, when the money is used to get land for an expressway.

It's pretty hard to put a value on public recognition.

Bob H

This may depend how much your SHPO rep does for you. Here in New York for a nomination I made a few years ago, our SHPO rep came to the site, took his own pictures, then wrote the actual submission to the state review board which meets quarterly. He let me review and correct the text before he submitted it, but I didn't see what pictures or their format that went with submission. Turns out this submission passed the state review board, i.e., we got state historic listing for the trolley, but the NPS did not accept it to the NR.

Just last month I submitted two more new nominations which were approved by the CLG...we'll see soon if the process changed at all. I think we'll have the same SHPO rep as before.

To summarize the flow of a NR nomination:

your nomination -> CLG approval* -> SHPO approval & rework application as needed -> state historic review board approval -> NPS approval

*skip CLG approval if you are not in a CLG designated area

Thanks for the comments. Interurban - thanks for the effort and thought you put into your reply. It's nice to see that the only down side is the work involved. Personally, I like the idea of the credibility that a listing would bring. Armed with this I will discuss it within the organization to make sure everyone is on board.

Being on the National Register of Historic Places does not automatically prevent a historic property from being destroyed by a federally funded highway project. It does make it more difficult though.

The Transportation Act of 1966, as amended, includes a set of provisions known as Section 4(f). These provisions direct USDOT to not approve a project that 'uses' historic properties or publicly-owned recreation areas unless there is no feasible or prudent alternatives to that use. A use can include acquisition of a portion of the parcel, not just destruction of the whole property.

For the purposes of Section 4(f), a property just has to be determined eligible for the National Register in consultation with the SHPO. It does not have to be listed.

Section 4(f) applies projects approved by FTA and FRA, so it is not just about highway projects.

I have simplified the above for the purpose of this discussion. FHWA has much more information about it on their web site. FTA tends to use the FHWA guidance, but they are a bit different.

In my neck of the woods, Sound Transit is getting ready to tear down and replace a former Milwaukee Road trestle in Tacoma, WA that has been determined NRHP-eligible. They are doing it under the approval of FTA and are mitigating for it with measures developed through the parallel Section 106 process.

Paul

Paul Krueger
Seattle, WA