Volume 14 No. 2,
December 1998
Do You Have an Historic Aviation Property?
Would You Like to Know What You Can Do With It?

The United States Department of the Interior’s National Park Service has published a National Register Bulletin entitled “Guidelines for Evaluating and Documenting Historic Aviation Properties.” You can order your very own copy for free by calling the National Register reference desk at (202) 343-8012 or via e-mail at nr_reference@nps.gov.

TIGHAR’s Senior Archaeologist, Dr. Tom King (TIGHAR 0391CE) has some answers to frequently asked questions:

What can you do with this Bulletin?

A National Register Bulletin like this one (there are dozens of others, dealing with different kinds of historic properties, identification methods, and so on) has two basic purposes.

  1. If you’d like to nominate your airplane to be included in the National Register, these are the guidelines to use in doing so.
  2. If a Federal agency, or somebody seeking a Federal permit or funding, wants to do something that might change an airplane that could have historical importance, the responsible agency has to consider whether the airplane might be eligible for the National Register. If it is, the agency has to consider what effects its actions will have on the plane, and what might be done to mitigate those effects, following specific regulations (found at Title 36, Part 800 of the Code of Federal Regulations). The agency should use this bulletin in figuring out whether the airplane is eligible for the Register. If you’re concerned about an agency doing damage to an airplane you think is historic, you could use this bulletin in pointing out the plane’s historic value to the agency.

Why would I want my airplane to be listed on the National Register?

Some people are impressed by such registration.

Will that increase its value?

It might (see above).

Will “The Gummint” give me money for to fix up my National Register airplane?

Unlikely, but every now and then Congress decides to toss money in the direction of historic preservation projects, and inclusion in the Register is usually a prerequisite for getting some.

If I later decide I want to replace or change something on my National Register airplane will they kick me off the list?

Could be, if you change enough to make it lose its “integrity.”

TIGHAR’s Executive Director Ric Gillespie has this to say about how this publication came about and how useful it might be in the cause of aviation historic preservation.

This fifty-four page booklet has a history only slightly less tortured than that of the 1781 Articles of Confederation and is about as useful. The first draft, released for comment in early 1995, brought a storm of criticism from virtually every corner of the aviation historical community-including TIGHAR. In “Your Tax Dollars At Work” (TIGHAR Tracks Vol. 11, No. 3) we expressed our misgivings about the draft but vowed to do our best to help correct the problems. After many hours of donated work and face-to-face meetings in Washington, we ultimately concluded that the National Register of Historic Places was simply not an appropriate tool for protecting historic airplanes (see “Great Hammer, Lousy Screwdriver” Vol. 11, No. 4). No revised draft was ever circulated and the issue seemed to be mercifully dead. But a federally funded project is the only example of true immortality known to science and, three years later, “Guidelines for Evaluating and Documenting Historic Aviation Properties” appeared unheralded in the mailbox.

In all fairness, it’s not as bad as the initial draft and where it discusses conventional properties-buildings, structures, archaeological sites, etc., its advice is unremarkable. A superfluous section purporting to tell the story of “Aviation In American History” is merely shallow and poorly proofed rather than being biased and inaccurate. For example: “Goddard (Robert H., that is) undertook research during WWI that led to the development of a solid-projectile, which was used during WWII as the bazooka.” Make that “solid-propellant.” Some of the errors are pretty basic. Thoughout the booklet “hangar” is rarely spelled correctly. But it is in attempting to explain what airplanes are eligible for nomination to the National Register of Historic Places that the bulletin wanders from the obscure to the hilarious. In a section entitled “Evaluating the Integrity of Historic Aviation Properties” it carefully states that “a property must retain the key materials from its period of its significance” [sic] and that “a property whose historic features and materials have been lost and then reconstructed is usually not eligible.” So far so good, but then the bulletin goes on to explain that, because airplanes have various parts replaced during their service life, “As long as an aircraft retains the majority of its structural members, it should be considered the authentic aircraft.” So it looks like your J-3 Cub, re-engined and re-covered in 1998 and equipped with the latest avionics, is eligible for the National Register so long as most of its steel tube skeleton dates from the old days.

But wait. “Setting” – defined as “the physical environment of a historic property” – is a crucial factor in eligibility. The aircraft must be “in a setting which is appropriate to an aircraft and allows it to convey its significance as an aircraft. An example of an appropriate setting would be an air-related facility where the aircraft is maintained.” That means your historic 1998 J-3 Cub with the 1938 skeleton may be eligible for the National Register if you keep it down at the airport and not someplace weird like a museum. “The National Register generally excludes museum objects from being listed” because “museum objects do not have integrity of location and setting ...” even though all six (that’s right, six) of the intact aircraft now on the Register are in museums.

But – but sometimes a museum is not a museum. For example: the bulletin points out that the Hughes Hercules flying boat, although protected in a museum-like setting, still qualifies for the Register because it is “located in Long Beach, California, the site of its successful air tests.” The fact that the Spruce Goose was sold and removed to Oregon in 1992 seems to have escaped the notice of the National Park Service.

In the end, “Guidelines for Evaluating and Documenting Historic Aviation Properties” could well serve as a Bible for those who want the distinction of having an airplane listed on the National Register because, as with Holy Scripture, in its pages one can find justification for almost anything.

Additional comments from professionals in the field, Paul Chattey and Tim Smith.

“...my intentions are good, Oh, lord, please don’t let me be misunderstood!”

It is necessary to know what the National Register of Historic Places is all about before considering this bulletin. It evolved when Congress passed The National Historic Preservation Act of 1966. That act was, in part, a reaction to large “urban renewal” projects that eradicated numerous historic districts and neighborhoods across the country. The act, amended many times since 1966, is the foundation for the Federal government’s historic preservation program. The act 1) authorizes each state to have a State Historic Preservation Officer (whose role, among other things, is to maintain an inventory of historic properties in their state and generally provide the state’s input to Federal agencies on treatment of historic properties in the state); 2) directs Federal agencies to inventory their lands to locate, evaluate, and appropriately treat historic properties they own, 3) requires Federal agencies to take historic properties into account in planning their undertakings; and 4) establishes the National Register of Historic Places (which we’ll call the “NRHP” to save space).

What then, is the NRHP? Simply put, it is a list of buildings, structures, objects, and sites that the Federal government deems worthy of consideration in planning their activities. For most any other purposes, it is simply commemorative. It does NOT automatically protect something or turn it into a National Park or a museum. It recognizes that something important happened in a particular place, and it gives us a direct, physical connection to our history. In practice, it is much more complicated than that and you can fill a bookshelf with all the bulletins, guidelines, forms, and regulations that go with listing properties in the NRHP. The latest bulletin (one of about 40) is the subject of this article.

To be listed in or considered eligible for inclusion in the NRHP, a property must be historically significant somehow. The criteria for inclusion are a) association with important historic events, for example, Gettysburg Battlefield; b) association with important people, for example, George Washington’s Mount Vernon; c) important architectural works or examples of an important type, like High School Auditorium in Mariopsa, California as an example of the Spanish Revival architectural style; and d) properties which contain information important in prehistory or history. This criterion was added to include archaeological sites.

Further, a NRHP property must have integrity. That is, it must look more or less like it did during its period of significance. In practice this is also a good bit more complicated. But, to boil it all down, a property’s got to be historically significant for solid reasons, and its got to be pretty much original.

Moving on to the purpose of this bulletin, the NRHP was invented to deal with buildings, structures, sites and objects: things that don’t move about. Airplanes don’t really fit, with some exceptions. This bulletin explains in the necessary detail how one may list airplanes in the NRHP and it does a fairly good job of that. It deals rationally with the issue of integrity for aircraft that have a major portion of parts replaced on a regular basis. It deals sensibly with the issue of aircraft as moveable objects. Most of the bulletin deals with aviation-related properties like airports, hangars, factories, and so on-properties that make up the vast field of aviation history.

Since airplanes are what TIGHAR members are most interested in, we’ll be surprised if more than a few members follow this discussion with riveted interest. (Just seeing if you’re awake.) Generally, the NRHP is of interest to cultural resource managers and consultants who are part of the planning process for government projects. While the NRHP is useful to these folks as a planning tool, it fails in other areas. Try filling out a NRHP nomination form some time. It is not fun and very few people do it for free or even cheaply. An on-line database of NRHP properties is available at Properties. While access to the data has been improved over the last few years, the National Park Service does not have the funds to make the system user-friendly or provide more than superficial information about individual properties. Regarding finances, it has been many years since federal grants were available to restore NRHP properties (that ended shortly after Ronald Reagan took office). Still, some income-producing properties are eligible for a tax credit to ease the cost of restoration.

Back to the bulletin. What it does not do well is provide the context for the importance of aviation in American History. The 4½ page section “Aviation in American History” is, as Ric says, not useful. That’s because no one can cover aviation’s complex history very well in four or even five pages. Also, drafting the bulletin was a government contract job. It went to the lowest bidder. You sometimes get what you pay for. The bibliography is much more useful.

To address some of Ric’s comments briefly: The J-3 Cub example is an interesting one. In our experience, there is a broad continuum of significance. We’ve participated in evaluating hundreds, maybe thousands by now, of buildings, structures, objects and sites for NRHP eligibility. After a while, you develop a feel for it. There are things that are clearly not eligible. There are things that are just as clearly eligible. But then, there’s a bunch of stuff in a big gray area, like Ric’s J-3. If it were ever necessary to do so, eligibility of a particular Cub would be decided on its individual history and the degree of modifications over the years. There are certainly Cubs that are more original than others. But, the alert reader may ask, what about Criterion C? Isn’t the J-3 an example of a significant type? Yes, but is it the original prototype? Is it the last remaining Cub? Is it the best-known example? Just because it is more than 50 years old does not automatically make it eligible for listing in the NRHP.

The issue of museum objects and the NRHP is a little complicated. First, there is no practical use in listing a museum object in the NRHP. Unless a museum goes bankrupt, it is already protected to a degree and, should a museum go belly up, NRHP listing won’t help. I would speculate that most of the museum planes that Ric mentions were not in museums when they were listed. One of Alaska’s NRHP aircraft was still hauling fish when it was listed but now is retired to a museum. It is still listed because nobody has asked the Park Service to take it off the NRHP.

Ultimately, the NRHP is just a list like any other. The NRHP’s ties to federal planning and preservation programs have turned the NRHP into something about as complex as the FARs. As an official list, we can reasonably expect that updating it and performing required maintenance will take a little longer than a similar list in the private sector. Unfortunately for most of us, getting something listed in the NRHP, and thereby simply recognizing something that people want to honor, is like trying to herd cats.

Moving right along, let’s go find AE.

Tim Smith (1142CE) was an archaeologist on the staff of the Alaska State Historic Preservation Officer from 1982-86 and 1990-1999. He was in charge of the Review & Compliance Program (seeing that the Feds follow their own regulations concerning cultural resources). He was assigned to deal with aircraft issues as they arise simply because of his interest in them.

Paul Chattey (1120C) is an architectural historian. From 1983 to 1988, he learned and applied the arcane skill of writing and editing nomination forms to list properties in the NRHP while on staff of the Alaska State Historic Preservation Officer. He is now with the National Park Service in Hawaii, where there are some airplanes.

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