Performance audit: Department of Natural Resources, results-based budgeting and coordination activities of the Historic Preservation Division

Performance Audit
Prepared For The Budgetary Responsibility Oversight Committee
Department of Natural Resources
Results-Based Budgeting and Coordination Activities of the Historic Preservation Division

May 2002

Russell W. Hinton, State Auditor Performance Audit Operations Division 254 Washington St., S.W.

Department of Audits and Accounts

Atlanta, GA 30334-8400

Background
The Historic Preservation Division (HPD) of the Department of Natural Resources (DNR) seeks to identify, protect and preserve Georgia's historic and archeological sites by providing historic preservation services and assistance to governmental agencies, private organizations, and individuals. The Commissioner of DNR serves as the federally mandated State Historic Preservation Officer (SHPO) for Georgia, which makes HPD responsible for performing certain historic preservation activities in the state on behalf of the federal government.
HPD is comprised of 36 employees (the HPD Director, the Director's Administrative Assistant, and 34 employees in five units). The main historic preservation services provided by HPD's units are described below.
Planning and Local Assistance Unit The Unit coordinates evaluations of Environmental Reviews. The Environmental Reviews are reports primarily prepared by outside consultants to assess the impact of state and federal construction projects (including projects by contractors or licensees) on historic resources. HPD staff read these reports to determine the anticipated impact of a project. If a project is anticipated to have an adverse impact on historic resources, HPD negotiates with the project's owner to mitigate the impact. In addition, Unit personnel provide technical assistance for state-wide historic preservation planning. Unit staff and contracted personnel at Regional Development Centers also provide technical assistance to local governments for their historic preservation planning. The Unit assists local governments in obtaining designation as a Certified Local Government (CLG), which indicates that the local government meets federal requirements for integrating historic preservation concerns with local planning decisions. With the assistance of other HPD units, the Unit's seven staff coordinated evaluations of over 3,900 Environmental Reviews in fiscal year 2001. The Unit also assisted two local governments in becoming CLG's and provided assistance to 61 previously certified CLG's.
Archaeological Services Unit The Unit promotes the preservation and protection of archaeological sites in the state. Unit personnel conduct site visits to assess the impact of DNR construction projects on potentially significant archaeological sites. Unit personnel conduct training and outreach programs for

Results-Based Budgeting and Coordination Activities of the Historic Preservation Division

Page 1

the public and other government entities on archaeology. Unit personnel also assist with evaluating Environmental Reviews and potential archaeological sites identified in Environmental Reviews are recorded in Archaeological Site Files that are maintained for HPD by the University of Georgia. The Unit's six staff conducted 31 archaeological site visits in fiscal year 2001 and over 2,500 potential archaeological sites that were reported by HPD and other sources were recorded in the Archaeological Site Files.
Survey and National Register Unit The Unit collects and records information about historic properties throughout the state and contracts for surveys of potentially historic properties. Unit personnel provide technical assistance and review/approve applications for properties nominated for listing in the National Register of Historic Places. (The National Register is the "country's official list of historic buildings, structures, sites, objects, and districts worthy of preservation."). Unit personnel also administer the Centennial Farms Program to recognize farms over 100 years old, assist with evaluating Environmental Reviews and assist with processing tax incentive applications. The Unit's seven staff processed 32 listings containing over 1,800 properties for listing on the National Register and recorded over 1,800 structures as potentially historic in fiscal year 2001.
Technical Services Unit The Unit administers three tax incentive programs to encourage the rehabilitation of historic properties including: the Federal Rehabilitation Investment Tax Credit which effectively reduces the costs of rehabilitation to owners of income producing property; the Charitable Contribution Deduction which provides a one-time tax deduction for the value of a commitment to preserve the historic attributes of a historic structure, and the State Preferential Property Tax Assessment Program which freezes property tax for rehabilitated property. Unit personnel also provide architectural and technical assistance to property owners and assist in evaluating Environmental Reviews and grant projects. The Unit's five staff approved 89 properties for tax incentives in fiscal year 2001. (57 for both Federal Rehabilitation Investment Tax Credit and State Preferential Property Tax Assessment eligibility, 31 for only State Preferential Property Tax Assessment eligibility, 1 for only Federal Rehabilitation Investment Tax Credit, and 0 for Charitable Contribution Deduction eligibility).
Management and Information Unit The Unit handles the administrative needs of HPD. Unit personnel coordinate AfricanAmerican preservation programs and outreach programs to the public and historic preservation professionals. The Unit awards Georgia Heritage Grants. These grants are awarded on a statewide competitive basis to local governments and nonprofit organizations for the preservation of historic properties. In addition, the Unit awards federal Historic Preservation Fund Grants. These grants are Predevelopment, Survey, and Planning grants that are awarded annually on a 60/40 matching basis to Certified Local Governments for projects that enhance historic preservation in local communities. The Unit's nine staff awarded 25 Georgia Heritage Grants totaling $307,000 and 15 Historic Preservation Fund Grants totaling $89,000 in fiscal year 2001.

Results-Based Budgeting and Coordination Activities of the Historic Preservation Division

Page 2

The fiscal year 2001 expenditures for HPD were approximately $3.9 million. HPD's funding included $3,092,954 (80%) in state funds and $768,823 (20%) in federal funds. HPD's fiscal year 2002 budget is approximately $3.7 million, which includes $3,021,132 (82%) in state funds and $669,093 (18%) in federal funds. The Division's Federal funds come from the Historic Preservation Fund, which is administered by the National Park Service.
Audit Scope and Methodology
This performance audit was conducted at the request of the Budgetary Responsibility Oversight Committee (BROC) as authorized by O.C.G.A. 28-5-5. The scope of the audit focused on the issues identified by BROC that are listed below:
Comment on and evaluate the validity and reliability of the data used in the Historic Preservation Division's Results-Based Budgeting goals.
To what extent is there coordination between federal, state, and local government programs? How does Georgia compare to other states?
The audit was conducted in accordance with generally accepted government auditing standards for performance audits. During the course of the audit, the audit team reviewed HPD records and interviewed HPD personnel. The audit team also conducted a customer satisfaction survey of individuals, private sector companies, and other government entities that received services from HPD. In addition, representatives of other government and private sector organizations that are involved with historic preservation activities in the state (including the National Park Service, other Georgia state government entities, and the Georgia Trust for Historic Preservation) were interviewed regarding their relationships with HPD.
The entire report was discussed with appropriate personnel at the Department of Natural Resources. DNR personnel were invited to provide a written response to the report and indicate areas in which corrective action was planned. Pertinent responses from DNR are reflected in the report as appropriate.

Issue: Comment on and evaluate the validity and reliability of the data used in the Historic Preservation Division's Results-Based Budgeting goals.

The Historic Preservation Division's Results-Based Budgeting goal and desired results are valid indicators of its activities. The Budget Accountability and Planning Act of 1993 requires that programs provide data in their Results-Based Budget (RBB) to indicate how well they are solving the problems they were created and funded to address. The intent of capturing and reporting such data is to reflect the progress the Program has made towards achieving its purpose for existing. HPD's goal and desired results measures, which are included in the fiscal year 2003 Governor's Budget Report, are shown in Exhibit 1 on the next page.

Results-Based Budgeting and Coordination Activities of the Historic Preservation Division

Page 3

Exhibit 1 HPD Results-Based Budgeting Goals and Desired Results
Fiscal Year 2003

DEPARTMENT OF NATURAL RESOURCES Results-Based Budgeting

HISTORIC PRESERVATION PROGRAM
Purpose: Identify, protect and preserve Georgia's historic places and archaeological sites for the use, economic benefit, education and enjoyment of present and future generations.

Goal 1: Georgia's Historic sites will be identified and preserved through state and local community preservation activities.

Desired Result 1a: The number of historic properties in Georgia that are identified by historic and archaeological

surveys.

Desired Result

FY 1998 NA

FY 1999 NA

FY 2000 NA

FY 2001 98,0001

FY 2002 95,500

FY 2003 101,000

Actual Result

NA

NA

85,252

91,151

Desired Result 1b. The number of historic properties in Georgia that are listed in the National Register of Historic

Places.

FY 1998 FY 1999

FY 2000

FY 2001

FY 2002

FY 2003

Desired Result

NA

43,862

54,562

52,500

53,500

54,500

Actual Result

47,212

50,548

52,087

52,570

Desired Result 1c. The number of state owned historic properties that are identified or protected as a result of HPD's

technical assistance. (Properties identified or preserved were submitted as one number.)

FY 1998 FY 1999

FY 2000

FY 2001

FY 2002

FY 2003

Desired Result (#Identified/#Protected) NA

32

40

27

50

50

Actual Result (#Identified/#Protected)

NA

22

37

52

Desired Result 1d. The number of "effective" [1] community historic preservation programs as determined by an annual

survey.

FY 1998 FY 1999

FY 2000

FY 2001

FY 2002

FY 2003

Desired Result

NA

NA

NA

NA

163

183

Actual Result

NA[2]

19[2]

15[2]

143

Note 1: Effective community programs include established programs that directly promote the preservation of historic resources at the

local level. Examples include: "Mainstreet" programs, Better Hometown Programs, Certified Local Governments and the like.

Note 2: The previous years (FY 1998 FY 2000) actual results for this measure were deleted due to poor data quality.

Desired Result 1e. The number of historic properties that are being preserved as documented by the use of the Federal

Rehabilitation Investment Tax Credit and the State Preferential Property Tax Assessment Program for Rehabilitated

Historic Property.

FY 1998 FY 1999

FY 2000

FY 2001

FY 2002

FY 2003

Desired Result

NA

NA

450[1]

350[1]

90

90

Actual Result

NA

437[1]

278[1]

91

NA

NA

Note 1: The previous years (FY 1998 FY 2000) actual results for this measure were deleted due to poor data quality.

Desired Result 1f: The number of historic properties that are preserved through HPD's grant assistance program.

FY 1998 FY 1999

FY 2000

FY 2001

FY 2002

FY 2003

Desired Result

NA

NA

NA

20

30

30

Actual Result

NA

NA

NA

25

1 Publication Error FY 2001 Desired Result 1a should have been reported as 90,000 Source: Governor's Budget Report Fiscal Year 2003

HPD's goal and six desired results are valid indicators of its activities. HPD's desired results were recently revised and updated with the assistance of the Office of Planning and Budget. HPD's goal is directly related to HPD's purpose and HPD's current desired results are all related to its goal of identifying, protecting and/or preserving historic and archeological sites in the state. As shown in Exhibit 2, all five of HPD's units have one or more desired results reporting on their activities. HPD's desired results measures are also very similar to activity data compiled by the National Park Service to monitor state historic preservation efforts. In addition, only three of

Results-Based Budgeting and Coordination Activities of the Historic Preservation Division

Page 4

six southeastern states contacted by the audit team had performance measures for their historic preservation activities and HPD's measures were more comprehensive than the measures reported by the other states.

Exhibit 2

HPD Desired Results and Units Involved with Activity

Desired Results

HPD Unit(s)

1a The number of historic properties in Georgia that are identified by historic and
archaeological surveys.
1b The number of historic properties in Georgia that are listed in the National
Register of Historic Places.
1c The number of state owned historic properties that are identified or protected
as a result of HPD's technical assistance. (Properties identified or preserved were submitted as one number.)
1d The number of "effective" community historic preservation programs as
determined by an annual survey.
1e The number of historic properties that are being preserved as documented by
the use of the Federal Rehabilitation Investment Tax Credit and the State preferential Property Tax Assessment Program for Rehabilitated Historic Property.
1f The number of historic properties that are preserved through HPD's grant
assistance program.
Source: Governor's Budget Report Fiscal Year 2003 and HPD Records

Archaeological Services Unit, Survey and National Register Unit Survey and National Register Unit Archaeological Services Unit, Planning and Local Assistance Unit Planning and Local Assistance Unit
Technical Services Unit
Management and Information Unit

Actual results reported for fiscal year 2001 on two of HPD's six desired results measures were adequately supported. The actual results reported for HPD's four remaining desired results were not adequately supported; however, the audit team's calculations of actual results for these four desired results only ranged from 8% percent less to 3% more than what had been reported in the Governor's Budget Report. Problems with the numbers reported in the Governor's Budget Report were primarily due to HPD's use of estimates and weak data collection techniques.
Exhibit 1 on page 4 shows HPD's goal and six desired results measures identified in the Governor's Budget Report. As shown in the notes in Exhibit 1, problems with the quality of reported actual results for two of the measures in prior years had already been identified. In addition, the audit team also identified that HPD did not intend for the Governor's Budget Report to show desired and actual results for the years prior to 2001 for Measures 1B, 1C, 1D, and 1E because the measures were significantly revised. Historical data that was not comparable to the revised measures was incorrectly included in the published report. Therefore the audit team focused on evaluating the reliability of the actual results reported for fiscal year 2001.
The team was able to verify the reliability of the actual results reported for two of HPD's six desired results measures. (Desired Result 1d "The number of effective community historic preservation programs as determined by an annual survey." and Desired Result 1f "The number of historic properties that are preserved through HPD's grant assistance program.").
Problems with the reliability of actual results reported in the Governor's Budget Report for HPD's four remaining desired results are discussed below.
Desired Result 1a (The number of historic properties in Georgia that are identified by historic and archaeological surveys.) The data used by HPD to generate the number

Results-Based Budgeting and Coordination Activities of the Historic Preservation Division

Page 5

reported in the Governor's Budget Report was not retained, and therefore could not be reviewed. In order to gauge the number's accuracy, the audit team identified the number of historic surveys and archaeological surveys completed as of the date of our review (November/December 2001). As shown in Exhibit 3, the audit team found about 3% more surveys than were reported in the Governor's Budget Report. The team's calculation included about 8% more Historic Surveys and about 5% fewer Archaeological Surveys than were included in the total number reported in the Governor's Budget Report. HPD personnel stated that the number of archaeological site surveys used for the Governor's Budget Report was based on an estimate and the number of historic site surveys was based on preliminary classifications of site surveys which may have changed after verification by the Program.

Exhibit 3

Verification Differences in Desired Result 1a

Reported in RBB Audit Team Calculation

Difference

(6/30/01)

(Nov./Dec. 2001)

#

%

Historic Surveys

53,151

57,367 4,216 8%

Archaeological Surveys

38,000

36,167 (1,833) ( 5%)

TOTAL 1a

91,151

93,534 2,383 3%

Sources: 2003 Governor's Budget Report and Verifications of Program Data by the Audit Team

Desired Result 1b (The number of historic properties in Georgia that are listed in the National Register of Historic Places.) HPD did not have documentation to support the 52,570 properties it reported in the Governor's Budget Report as listed in the National Register. HPD staff stated that the reported number probably came from a query of their database of historic properties; however documentation of the query was not maintained. The National Park Service, who maintains the National Register, reported that there were 53,612 properties (1,042 or 2% more properties) on the Register at the end of fiscal year 2001. HPD agreed that they would develop a way to use the National Park Service count of properties on the National Register in the future.

Desired Result 1c (The number of state owned historic properties that are identified or protected as a result of HPD's technical assistance.) The data used by HPD to generate the number reported in the Governor's Budget Report was not retained, and therefore could not be reviewed. As shown in Exhibit 4, HPD reported 52 properties were protected in fiscal year 2001, but the audit team was able to verify only 48 properties (8% fewer).

Exhibit 4

Verification Differences in Desired Result 1c

Reported in RBB Audit Team Calculation Difference

(6/30/01)

(6/30/01)

#

%

Sites Identified on DNR Land

37

31 (6) (16%)

State Stewardship Projects

15

17 2 13%

TOTAL 1c

52

48 (4) ( 8%)

Sources: 2003 Governor's Budget Report and Verifications of Program Data by the Audit Team

Results-Based Budgeting and Coordination Activities of the Historic Preservation Division

Page 6

HPD personnel thought that the number of Sites Identified on DNR Land reported in the Governor's Budget Report was probably an estimate and indicated that an accurate count of State Stewardship Projects is difficult because of inconsistency in labeling those projects in their files.
Desired Result 1e (The number of historic properties that are being preserved as documented by the use of the Federal Rehabilitation Investment Tax Credit and the State Preferential Property Tax Assessment Program for Rehabilitated Historic Property.) HPD reported 91 properties as receiving tax incentives in fiscal year 2001 based on a query of their database showing the total number of state tax incentive projects. HPD personnel indicated they did not attempt to include federal projects in the count since they felt that practically all the federal projects were also state projects. The audit team counted the individual projects and found only 88 state projects and one federal project that was not also a state project for a total of 89 projects (2% fewer than reported). HPD agreed that the number reported in the Governor's Budget Report did not reflect the actual number of properties using tax incentives because the database did not include all federal projects and somehow included too many projects classified as state projects.
The audit team also found that three of HPD's six desired results represented cumulative activity (Desired Result 1a, Desired Result 1b, and Desired Result 1d); however, the descriptions for these desired results in the Governor's Budget Report did not indicate that they represented cumulative activity. The descriptions for these desired results need to clearly identify that cumulative numbers are being reported so they are not misinterpreted as being indicators of annual activity.
HPD agreed to start maintaining better documentation of its calculations of actual results to support the numbers reported in the Governor's Budget Report and to provide guides so the actual results are calculated and reported consistently in future years. HPD also agreed that management would review the supporting data for desired results reported in the Governor's Budget Report to ensure that the reported numbers are properly calculated and that estimates are not used. In addition, HPD agreed to identify the cumulative nature of the three desired results that represent cumulative activity in future Governor's Budget Reports.

Issue: To what extent is there coordination between federal, state, and local government programs? How does Georgia compare to other states?
The audit team's observations, interviews with representatives of entities involved with historic preservation, and a survey of certain HPD customers all indicated that HPD does a good job of coordinating their efforts with the activities of other federal, state, and local government programs involved with historic preservation in Georgia.
The audit team did not observe any duplication of effort or any other indications of poor coordination with other government entities during reviews of HPD's operations.

Results-Based Budgeting and Coordination Activities of the Historic Preservation Division

Page 7

Representatives of historic preservation programs in five other southeastern states reported two primary mechanisms for coordinating historic preservation activities. All five of the other states indicated that coordination with federal historic preservation activities is achieved through the federal designation of a State Historic Preservation Officer (SHPO). Three of the other states indicated that coordination with local government operations was achieved through local government participation in the National Park Service's Certified Local Government Program. HPD is responsible for assisting DNR's Commissioner who is designated as the State Historic Preservation Officer (SHPO) for Georgia. Georgia also has one of the most active Certified Local Government Programs in the country.
The audit team interviewed personnel from various entities involved with historic preservation in Georgia (including the National Park Service, the Georgia Department of Transportation, the Georgia Trust for Historic Preservation, and a private company). The interviews did not identify any coordination problems and the consensus of the interviews was that HPD did a good job of coordinating their efforts with other government programs involved with historic preservation activities.
The audit team also conducted a survey of certain HPD customers in order to solicit their input regarding how HPD coordinates its activities with other government programs. HPD's customers were asked to rate HPD's coordination with other entities such as local governments, other state programs, and federal government programs. Ninety customers responded to the survey, of these 21 indicated they were "unsure" and did not rate HPD. As shown in Exhibit 5 below, 53 (77%) of the remaining 69 customers rated HPD's coordination with other government entities as `good' or `excellent'. While three of the customers rated HPD's coordination as `poor', follow-up interviews with these customers did not identify any significant problems.

Exhibit 5 Survey Respondent's Ranking of HPD's Coordination Activities

Excellent (20 of 69)

29%29%

4 %
4%

Poor (3 of 69)

77%
Good (33 of 69)

48% 48%

19% % 19

Fair (13 of 69)

Source: Survey of HPD Customers

Results-Based Budgeting and Coordination Activities of the Historic Preservation Division

Page 8

HPD ranked in the top 10 states for most of the measures of activity compiled on state historic preservation operations by the National Park Service. In addition, interviews with representatives of entities involved with historic preservation in Georgia and a survey of certain HPD customers indicated that Georgia compares favorably to other state historic preservation programs.
National Park Service Data As shown in Exhibit 6 below, based on state data compiled by the National Park Service (NPS), Georgia ranked 26th in terms of state and local funding but ranks in the top 10 in five of seven activities measured by NPS and ranked 8th in federal funding allocation. While such rankings are obviously influenced by factors beyond the control of state historic preservation operations (such as the size of the state and the number of historic properties in a state) higher rankings are an indication of a program's effectiveness as compared to historic preservation programs in other states.

Exhibit 6 Rank in Selected Activities and Funding
(Federal Fiscal Year 2000)

HPD Unit

NPS Annual Activity Data Available

Rank

Number

Range of all states

Archaeological Services

Hectares1 added

7

193,955

0 - 877,255

Number of Listings Added

to National Register

19

Survey and National Number of Properties

Register

added to National Register

7

Properties added to Survey Inventory

1

Planning and Local

Number of Certified Local Governments

3

Assistance

Environmental Reviews (actions reported)

23

32 1,411 11,008
64 2,732

1 - 129 3 - 6,554 0 - 11,008 2 - 108 258 - 10,462

Technical Services Tax Incentives

7

$55.4 million $0 - $334.3 million

FUNDING

State and Local Funding

26

Federal Funds Allocation

8

$492,524 $753,555

$142,568 - $1,631,980 $331,724 - $934,281

1 Hectare is equal to 10,000 square meters (2.471 acres) Source: National Park Service

Interviews with Representatives of Entities Involved with Historic Preservation The audit team interviewed personnel from various entities who were knowledgeable about historic preservation programs in Georgia and other states (including the National Park Service, the Georgia Department of Transportation, the Georgia Trust for Historic Preservation, and a private company). The consensus of the interviews was that Georgia had a good historic preservation program compared to other states.

Results-Based Budgeting and Coordination Activities of the Historic Preservation Division

Page 9

Survey of HPD's Customers The audit team also conducted a survey of certain HPD customers in order to solicit their input regarding how HPD compared to historic preservation programs in other states in regards to quality of service and coordination with other entities. As shown in Exhibit 7, the survey of HPD customers found that 87% (26 of 30) of the customers rated HPD as `good' or `excellent' compared to historic preservation programs in other states. One customer rated HPD as `poor' compared to programs in other states; however, a follow-up interview with the customer did not identify any significant problems.
Exhibit 7
Survey Respondent's Ranking of HPD as Compared to Historic Preservation Programs in Other States

Excellent (9 of 30)
87%
Good (17 of 30)

30% 30 %
57%
% 57

3 %
3%
10% 10 %

Poor (1 of 30)
Fair (3 of 30)

Source: Survey of Customers

Other Issues
HPD needs to continue efforts to reduce the processing times required for listing properties on the National Register of Historic Places. A review of listings added to the National Register during the 12-month period ending in September 2001, found that it took on average 4.2 years for a property to be listed (with a range of 1.6 years to 8.2 years).
A review of the 39 listings added to the National Register during the 12-month period ending in September 2001 found that it took on average 4.2 years for a property to be listed (with a range of 1.6 years to 8.2 years). The audit team's survey of HPD customers found that 51.4% (18 of 35) of the customers seeking to list a property on the National Register rated the timeliness of HPD's processing of their nomination as `fair' or `poor'. In comparison, a Performance Audit issued in January 1994 found that new listings on the National Register during fiscal year 1992 took on average 3.5 years (with a range of 11 months to over 10 years) and that 31% (6 of 19) of the National Register customers surveyed rated the timeliness of HPD's processing of their nomination as `fair' or `poor'.

Results-Based Budgeting and Coordination Activities of the Historic Preservation Division

Page 10

Data to compare Georgia to other states in terms of timeliness of their National Register listing process was unavailable since the National Park Service does not collect data on how long it takes for a nomination to be listed. The 1994 Performance Audit was also unable to identify a benchmark to gauge timeliness; however the audit did note that the National Register timeliness problem appeared to be widespread throughout the nation.
HPD management stated that they are aware of problems with the timeliness of the National Register nomination process. HPD management indicated that the probable causes of the problem include: an increase in requests for nominations with no increase in staff; difficulty in retaining and hiring staff; and, an increase in the number of Environmental Reviews that staff in the Survey and National Register Unit assisted in evaluating.
HPD reported that it is redesigning the National Register nomination application to help cut down on requests for more information from applicants, and is conducting bi-monthly staff reviews of nominations to help prioritize activities. HPD management also reported that the Division has requested, but did not receive, two additional staff in fiscal year 2000, one in fiscal year 2001, and one in fiscal year 2002 for the Unit that performs Environmental Reviews. HPD thought that these additional resources would result in additional staff resources for National Register activities once the National Register staff are freed from their Environmental Review responsibilities.

HPD needs to continue efforts to reduce the processing times required for evaluating Environmental Reviews. A review of 46 Environmental Reviews in process at the time of this audit found that nearly 24% took longer than the allowed 30 days.
Environmental Reviews are reports prepared by outside consultants that identify the impact that a proposed construction project may have on any potentially historic resources. HPD staff read these reports to determine the anticipated impact of a project. If a project is anticipated to have an adverse impact on historic resources, HPD negotiates with the project's owner to mitigate the impact.
Under federal regulations, HPD has 30 days to evaluate an Environmental Review once it receives a report. A construction project may continue even if the Program's evaluation is not completed; however the project's owner is still required to mitigate any adverse impact once it has been identified by HPD. While HPD does not maintain data to monitor its compliance with the federal 30-day requirement, a review of 46 completed Environmental Reviews identified 11 (23.9%) that were overdue an average of 27 days (ranging from 2 to 39 days). The audit team's survey of HPD customers found that 33% (12 of 36) of the customers submitting Environmental Reviews for evaluation rated the timeliness of HPD's processing of their submissions as `fair' or `poor'.
HPD management stated that they are aware of a problem with the timeliness of processing their evaluations of Environmental Reviews. HPD management said that the probable causes of the problem include: a dramatic increase in workload with no increase in staff size. HPD reported that they evaluated 1,376 Environmental Reviews in fiscal year 1996 with five staff and 3,979 Environmental Reviews in fiscal year 2001 HPD with five staff. HPD also noted that

Results-Based Budgeting and Coordination Activities of the Historic Preservation Division

Page 11

vacancies/workload in the Planning and Local Assistance Unit has required that personnel in other units help with evaluations of Environmental Reviews.
HPD management reported that they have requested, but did not receive, two additional staff in fiscal year 2000, one in fiscal year 2001, and one in fiscal year 2002 for the Planning and Local Assistance Unit. HPD reported that it is also working on filling vacant positions and upgrading positions in this unit, which is responsible for Environmental Reviews, so the reviews can be evaluated more quickly and efficiently.

For additional information, please contact Paul E. Bernard, Director, Performance Audit Operations Division, at (404) 657-5220.

Results-Based Budgeting and Coordination Activities of the Historic Preservation Division

Page 12

Locations