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Traditional cultural properties: what they are and why NPS now uses ‘traditional cultural places’

Learn what traditional cultural properties are, why NPS now uses traditional cultural places, and how TCPs fit into the National Register and Section 106.

Ancient petroglyphs etched into red sandstone canyon walls in Moapa Valley, Nevada.
Photo by Petra Nesti on Pexels

Traditional cultural properties, usually shortened to TCPs, are places whose significance comes from an ongoing relationship with a living community and the beliefs, customs, or practices that help sustain that community's cultural identity.

The term traditional cultural property is still common in preservation, cultural resource management, Section 106 records, agency manuals, state guidance, older agreements, and court decisions. But the National Park Service updated its National Register guidance in 2024 and now uses the phrase traditional cultural place. The acronym TCP remains the same, so practitioners may encounter both terms in current project records.

That terminology change didn't create a new National Register category or change the underlying test. A TCP still has to be a physical place that fits one of the National Register's recognized property types and satisfies the applicable significance, integrity, and procedural requirements.

What is a traditional cultural property or traditional cultural place?

In current National Register practice, a traditional cultural place is a building, structure, object, site, or district that may be listed in, or determined eligible for, the National Register because it is significant to a living community through cultural beliefs, customs, or practices rooted in that community's history and important in maintaining its cultural identity.

The place can be heavily built, lightly modified, or largely natural in appearance. A TCP might be a church, neighborhood, trail, ceremonial location, fishing area, landscape feature, cemetery, meeting place, or other physical location. What matters is the documented relationship between the place, the living community, and the historically rooted cultural practices or beliefs. Integrity still matters, but it has to be evaluated in light of that significance. The 2024 NPS Bulletin doesn't add separate National Register aspects called ‘integrity of relationship’ or ‘integrity of condition.’ Instead, it applies the familiar seven aspects of integrity and asks, among other things, whether the place has an essential relationship to the traditional beliefs or practices and whether that relationship endures despite change. Physical alterations, modern intrusions, or impaired access can matter when they weaken the place's ability to convey that significance or disrupt the community's continuing relationship with it.

For the broader federal framework, see Preserve Signal's guide to the National Register of Historic Places.

Why NPS changed ‘property’ to ‘place’

The older phrase traditional cultural property dates to the original National Register Bulletin 38 issued in 1990. In the 2024 revision, NPS changed the preferred term to traditional cultural place.

NPS explains that some traditional communities objected to the word property because it could imply commodification of their heritage. The revised bulletin therefore uses place, which also aligns more naturally with the National Historic Preservation Act's National Register of Historic Places terminology.

NPS says the definition of a TCP and the way TCPs are identified, documented, and evaluated didn't change. So older records using traditional cultural property and newer records using traditional cultural place can refer to the same National Register concept. The terminology shift also doesn't rewrite older agency manuals, state survey standards, programmatic agreements, determinations, or judicial decisions that use traditional cultural property. Those documents need to be read under the terminology and authorities that govern them.

A TCP isn't a separate National Register criterion

Traditional cultural significance isn't a fifth National Register criterion, and TCP isn't a sixth property type. A TCP must be a building, structure, object, site, or district and must be evaluated under the same National Register Criteria A-D and Criteria Considerations that apply to other properties.

What differs is the source and character of the significance. Community knowledge can be central evidence because the associated community is the authority on its own traditions and its relationship to the place.

For the evaluation framework itself, see Preserve Signal's guide to the National Register criteria and its companion article on historic significance.

What makes a traditional cultural place distinctive?

The 2024 NPS guidance emphasizes several characteristics. The place must be associated with and valued by a living community; the community must have historical continuity into the present; and the beliefs, customs, or practices associated with the place must be rooted in the community's history and continue to matter to its cultural identity.

For National Register TCPs, the period of significance generally extends to the present because the place continues to play an active role in transmitting cultural beliefs, customs, or practices. That doesn't mean the last 50 years create a separate eligibility problem simply because the period extends to the present. NPS guidance explains that if a place only came to be significant to a community for its beliefs, customs, or practices within the past 50 years, Criteria Consideration G may require exceptional importance and the place is unlikely to qualify as a traditional cultural place. By contrast, because a TCP's significance is rooted in an older tradition and continues into the present, NPS says Criteria Consideration G typically doesn't apply merely because the period of significance reaches the present. Recent changes can themselves be significant when they are consistent with the traditions that give the place value.

A tradition by itself isn't a National Register property. The National Register recognizes physical places. Intangible knowledge, ceremonies, stories, lifeways, or practices can establish why a place matters, but there must still be a building, structure, object, site, district, or physical location to evaluate.

TCPs aren't limited to Indigenous communities

Many of the best-known TCPs are associated with American Indian Tribes, Alaska Native communities, and Native Hawaiians, and federal law expressly recognizes that properties of traditional religious and cultural importance to Indian tribes or Native Hawaiian organizations may be eligible for the National Register.

But NPS is equally clear that TCPs aren't limited to Indigenous peoples. A living community of any cultural or ethnic background can have a place of traditional cultural significance if the place and community meet the National Register framework.

Current NPS examples include Greek American, Creole of Color, Czech American, fishing, ranching, and other communities. The key question isn't whether the group fits a particular ethnic category. It's whether the community has historical continuity and whether the place remains important to the beliefs, customs, or practices that maintain its identity.

A traditional cultural place isn't automatically a sacred site

TCP and sacred site are related concepts, but they aren't synonyms. Some TCPs are sacred or religious places. Others are important because of economic practices, community gathering, foodways, work traditions, social life, or other cultural relationships.

Likewise, a sacred site isn't automatically a National Register historic property. Federal sacred-site responsibilities can arise under authorities other than the National Historic Preservation Act, and a sacred site may or may not satisfy the National Register criteria.

This distinction matters in federal project review because an agency may have responsibilities concerning a sacred site even when the National Register eligibility question is unresolved or produces a different result.

Traditional cultural places and Section 106

A TCP that is listed in or eligible for the National Register is a historic property for Section 106 purposes. Formal National Register listing isn't required.

For a federal undertaking, the agency is responsible for making a reasonable and good-faith effort to identify historic properties and for evaluating properties under the National Register criteria in consultation with the appropriate preservation officials and consulting parties.

Federal law specifically requires consultation with Indian tribes and Native Hawaiian organizations that attach religious and cultural significance to historic properties that may be affected. That consultation responsibility isn't limited to places that have already been labeled TCPs in a survey or database.

For the review process, see Preserve Signal's Section 106 guide. For the formal tribal preservation role on tribal lands, see what a Tribal Historic Preservation Office does.

Community knowledge and confidentiality matter

Traditional cultural places can be easy for outside researchers to miss. A landscape feature may have little visible evidence of use, while its importance is well understood within the community that values it. NPS guidance therefore treats community-provided knowledge as an independent and essential line of evidence.

That doesn't mean every culturally sensitive detail belongs in a public report. The National Historic Preservation Act allows information about the location, character, or ownership of a historic property to be withheld from public disclosure in specified circumstances, including when disclosure could harm the property or impede use of a traditional religious site.

The updated TCP Bulletin also stresses confidentiality throughout identification and documentation and says a community's decision not to identify, discuss, or nominate a place should be respected.

That's particularly important when interpreting a historic resource survey. The absence of detailed public information doesn't prove that no culturally significant place or community interest exists.

Three examples in Preserve Signal's coverage area

The examples below show how different a TCP can look. Two are National Register listings discussed in the current NPS TCP Bulletin; the third illustrates a place determined eligible rather than separately listed as a TCP.

  • Tarpon Springs Greektown Historic District | Florida. Listed in the National Register in 2014, the district documents the continuing Greek American cultural community associated with Tarpon Springs' sponge industry, maritime traditions, religious life, and Greektown identity. Its period of significance extends from 1905 to the present.
  • St. Augustine Catholic Church and Cemetery | Louisiana. This Natchitoches Parish district was listed in 2014 for its significance to the Cane River Creole of Color community. NPS uses it as an example of a religious place whose continuing cultural significance can be evaluated under the National Register framework.
  • Ocmulgee Old Fields | Georgia. NPS planning documents describe the Ocmulgee Old Fields traditional cultural property as determined eligible for the National Register under Criterion A for its longstanding importance to Muscogee (Creek) culture and under Criterion D for its information potential. That eligibility is distinct from the separate National Register listing of Ocmulgee Mounds National Historical Park.

Why TCP identification can matter in project work

For project teams, identification of a potential TCP can change the questions that need to be asked. It may affect survey strategy, consultation, alternatives analysis, access considerations, treatment of sensitive information, or how effects are evaluated.

But identifying a TCP doesn't by itself mean that a project is prohibited, opposed by the associated community, or certain to result in mitigation. The implications depend on the property's status, the undertaking, consultation, effects, other applicable laws, and the decisions made through the relevant process.

For project-intelligence purposes, the strongest signal usually comes from connecting TCP or tribal-consultation records with other evidence such as environmental review, agency alternatives, design changes, permits, funding, agreements, or procurement.

The practical takeaway

Traditional cultural property remains an important search term and a common phrase in existing preservation records, but the National Park Service now uses traditional cultural place in its current National Register guidance.

The core concept hasn't changed: a TCP is a physical place whose significance to a living community comes from historically rooted cultural beliefs, customs, or practices that remain important to the community's identity. It must still fit the National Register framework, and understanding it often requires listening to the people who know the place through lived tradition rather than relying only on visible features or public databases.

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