Historic Preservation in Turkey and the United States: a Cross-Cultural Comparison

The research examines and compares the various roles of govern- mental and non-governmental organizations (NGOs) in Turkey and the United States, aiming to assess how they shaped the preservation field and their potential knowledge transfer values. The study was conducted in governmental archives, official websites of related orga- nizations and through oral communication and literature surveys related to preservation foundations, NGOs, and waqfs in both coun- tries - with different national, historic, religious, and cultural charac-teristics. The parameters used as cross-cultural comparison included The research has revealed that the has a deep-rooted historic, religious, and socio-cultural con- text, and differs from the preservation foundations in the USA in many respects. Yet, the foundations established in and after the 20 th century in Turkey and the preservation activities of foundations in both countries also share similar motives, stimuli, and objectives to preserve both natural/cultural heritage and cross-cultural comparisons suggest that they may learn from each other by knowledge transfer. The research covers the development of his- toric preservation, various preservation legislation, and organizations in both countries, a clarification of the roots and history of dif- ferent NGOs, foundation/waqf systems, and their role in preservation activities and the questions of “how” and “why” to preserve in each country. What follows is a cross-cultural comparison in the field held by as in order to develop a

The research examines and compares the various roles of governmental and non-governmental organizations (NGOs) in Turkey and the United States, aiming to assess how they shaped the preservation field and their potential knowledge transfer values. The study was conducted in governmental archives, official websites of related organizations and through oral communication and literature surveys related to preservation foundations, NGOs, and waqfs in both countrieswith different national, historic, religious, and cultural characteristics. The parameters used as cross-cultural comparison included primary actors and main legislations in preservation both in history and at present. The research has revealed that the waqf system in Turkey has a deep-rooted historic, religious, and socio-cultural context, and differs from the preservation foundations in the USA in many respects. Yet, the foundations established in and after the 20 th century in Turkey and the preservation activities of foundations in both countries also share similar motives, stimuli, and objectives to preserve both natural/cultural heritage and cross-cultural comparisons suggest that they may learn from each other by knowledge transfer.

Scientific Paper introDuction
Cul tural heritage is an important part of society's social, cultural, and economic wellbeing. Governmental institutions and the countries' private sector work together in the architectural preservation of the built heritage and in doing so, both national and international legislation, standards, and guidelines are applied. Existing approaches to architectural conservation mostly tend to seek an answer to "how" and "why" preserve (Ahunbay, 2004 Meeks and Murphy, 2016). However, to better understand the answers to these questions, it is also important to question the main actors in historic preservation and to ask the question of "who". Hence, in this study "how" and "why" to preserve is discussed shortly and due to the lack of literature on the efforts of preservation actors, it is aimed at examining the role of state institutions and private foundations, waqf 1 , and civil society organizations in historic preservation in the context of two different countries. Thus, the question of "who" is equally important and is in the focus of the paper.
Turkey and the United States, which have rather different legislations, organizations, and even terminologies in the preservation field, have been chosen as the case study countries. There is a limited number of stud-ies on the cross-cultural comparison of heritage preservation in the United States, Britain, Europe, and Asia (Barthel, 1989: Wang, 2007;Yeomans, 1994: 159-178). There are also quite a few studies on the preservation of built heritage by foundations and the waqf system in both Turkey (Akar, 2009; Dedehayır, 2010; Keskin, 2015;Madran, 1996Madran, , 1997Madran, , 2004Öztürk, 2007;Şahin and Güner, 2006) and the USA (Howe, 2003;Merrill, 1980;Mulloy, 1976;Murtagh, 1997;Wood, 2010). The studies focus on the preservation activities in each country, and thus lack a comparative context. However, cross-national and cross-local comparisons can be useful for transferring knowledge for contemporary studies (Alterman, 2010). In the same way, such a comparison is essential to understand the role of NGOs, state and community involvement, conservation mechanisms, and to reveal advantages and disadvantages in architectural preservation in both countries. That way both heritage regulation makers and heritage users of each country may learn from each other by transferring their strengths and/or re-arranging the weaknesses. The main arguments in favour of such a comparison of these two cases are presented below: − Despite the very differences in each country, there are also links and relationships in the preservation field/policies, and the preservation legislation in each country plays a similar role and functions to resolve problems/dilemmas in historic preservation practices. Therefore, by revealing links and comparing preservation practices and policies, practitioners in the preservation field might have the opportunity to exchange knowledge about alternative approaches to preservation and could benefit from a comparative experience in order to enhance the sustainability of built heritage. − Cross-cultural comparisons of two different countries with two long-established systems (waqf versus NGOs), should also enable legislators and practitioners (in both the public and private sector) to gain knowledge about an alternative legal framework, actors' participations/engagements, and their main stimulus/motivations in the heritage preservation, making it possible to come up with better solutions, face challenges, and avoid past failures. − Last but not least, such a comparison reflects various public, national, social, and cultural conditions of each country, making systematic mutual learning/development and sustainable management of heritage preservation a possibility in case they are well-analysed. This increases tourism potential related to built cultural heritage and presents a pool of similar challenges and opportunities in terms of preservation and urban development. In addition, both countries have their own preservation legislations, as well as adopted international preservation charters and conventions, dedicated to the enhancement of heritage preservation. Similarly, they both have a dynamic history hosting various identities, which influence the management, function, and owners of heritage buildings/ areas, and both of them were also influenced by their neighbours or multi-ethnic societies throughout history. Despite their different sizes, culture, and economy, public participation can be observed in preservation practices, affecting the cultural heritage management and development in both countries. There is also community involvement and public-private partnership in both Turkey and the USA, which has been beneficial for the preservation of different types and scales of cultural heritage. Lastly, in both countries, a master's program in historic preservation started in the same years, proving the increased level of consciousness and emphasis on the scientific importance of the preservation field.

MethoDoloGy of the research
Differences and similarities attract the attention of a deeper study which should reveal the very reasons and transfer potentials for the betterment of preservation studies in both countries.

1
Waqf means "to prohibit the selling or buying of an immovable and donate it for the use and welfare of the public" (Madran, 2004: 143

Preservation in turkey
In Turkey, until the mid-19 th century, Islamic provisions and the waqf system, first started in the Seljuk period and continued up till the end of the Ottoman period, provided the most effective regulatory system in the field of conservation. Regarding the questions of "why" and "how" to preserve; waqf institutions were based on charitable giving, serving God forever, and concepts of alms and offerings of the Koran, establishing many buildings or complexes such as mosques, madrasahs, baths, imarets, and hospitals 3 (Akar, 2021: 87-104). The philanthropic people, who established the waqf institution, also donated an income-generating property to this institution and ensured that the services, including repairs and maintenance works, were provided uninterruptedly in the institution. Waqfs include a written endowment deed to formalize all the donated goods and incomes and include information on their status, how the income was collected, and where and how it would be spent. It was in 1839 with the Tanzimat period that the institutionalization of the waqf system and legal regulations in repairs started (Madran, 2002: 14-15;Madran, 1996: 60; Dişli and Günel, 2020). Ebniye Regulations (1848), Municipal Provisions of Şehremenati (1855), and Turuk and Ebniye Charter (1864) all included indirect regulations on the repairs of cultural heritage, but it was in 1869 that the first legal regulation on the protection of cultural heritage (Asar-ı Atika) was adopted. In 1874, 1884, and 1906 the second, third, and fourth Ancient Monument Regulations were adopted, respectively. The Conservation of Monuments Act was adopted in 1912 for the protection of monuments from demolition that requires authorization, and in 1923 the Turkish Republic was established, so all the remains belonging to earlier cultures were accepted as the common heritage (Jokilehto, 2011: 245). In 1917, a conservation council, mostly responsible for the registry of monuments throughout Istanbul, was established and later, with a new regulation in 1924, renamed the Committee for the Protection of Old Monuments, making it compulsory for both the state and individual actors to take permissions from this new commission for any restoration interventions (Açıkgöz, 2014). In 1933, a new Commission, responsible for the conservation of monuments in the whole country, was established and giving impetus to national listing and documentation. In the Early Republican period , the restoration of monuments in Istanbul went through coordination problems and inter-institutional conflicts. There was also an intense restoration program, in most cases extending the building itself and causing the destruction of adjacent structures for the sake of increased visibility and modernization via urban transformation projects (Açıkgöz, 2014;Dinler, 2021). Açıkgöz (2014) interprets this situation as a kind of appropriation, either in the form of refunctioning of old monuments or 'stylistic, periodic, and dynastic classification' of heritage buildings all discursively aimed at emphasizing the national label, Turkish patrimony. He further argues that in the Early Republican period, historic preservation was an effective way to exhibit the nascent power of the nation-state and to increase its authority on society, while their diplomatic significance, national prestige, construction period, and patrons of the monuments were the primary factors affecting preservation decisions (Açıkgöz, 2014).
With the establishment of the first expert agency, the High Council (HC) for the Historic Real Estate and Monuments in 1951, new discussions on conservation began, such as conservation of historic areas as well as individual buildings, and HC operated as the scientific body of the centralized authority (Şahin-Güçhan and Kurul, 2009: 22, 26, 28;Dinler, 2021). Later, Antiquities Law No 1710 was accepted in 1973, which introduced the term 'conservation site' for the first time as part of "integrated conservation" (Dinler, 2021). The HC continued its duties until the adoption of the Law of 2863 on Conservation of Cultural and Natural Property in 1983. With the amendment of this Law, in 2004, some major changes were observable both in institutional and regulatory areas in preservation works. Thus, new responsibilities were given to the local governments, resulting in the increasing localization of the conservation activities (Table I). In addition, according to Aykaç (2021) with the establishment of the Turkish Cooperation and Coordination Agency (TİKA) in 1992, the Neo-Ottomanizm policy, first emerged in Turkey in the 1980s, accentuated the political, cultural, and economic influence of Turkey, including heritage conservation activities, in the regions where Ottoman Empire was dominated once over, and in early 2000, this policy was more strongly acknowledged. She further argues 3 As − The role of foundations in historic preservation in Turkey: history and development -In Turkey, non-governmental organizations (NGOs) have been active in the conservation field since the Ottoman period. The waqf system 4 of that period already demonstrated civil society solidarity, working for the sake of the public, including maintenance activities without any incentive, such that in the 19 th century, nearly 7% of the waqf income was allocated for the repair needs and expenses of the buildings. Under the conditions specified in the waqf deeds, the trustees conducted repairs for the most part before the Tanzimat period (before the mid-19 th century). Only when the income of the foundation was insufficient for repair, did the state treasury intervene. In addition, among the employees of the large foundations were there permanent workers, called 'meremmetci' responsible for regular maintenance and repair works (Madran, 2002: 9). Similarly, in the 19 th century, the first non-governmental organiza-tions on conservation and museology were first established. The Izmir Library and Museum Society (founded before 1878) is known as the first NGO in the conservation field in the late Ottoman period, requesting excavation and research permits from the governorship (Madran, 2002: 79). The Art Friends Society, founded by Osman Hamdi Bey, and the Turkish Association (1909) contributed indirectly to conservation studies through financial support or educational activities. The Assembly of Ottoman Engineers and Architects   [21][22]. Especially in the Classical Ottoman period, religion was a very important factor for the conservation of waqf buildings, and the waqf institution provided continuous maintenance, and repair works of cultural properties, enabling a mitigation of the effects of natural disasters, threats, and risks in order to ensure their survival without the need for comprehensive repairs. Yet, this value-based protection approach, unawareness, religious conservatism, and financial obstacles, also caused a decay of heritage buildings (Madran, 2004: 37, 140-141  − General tendencies and institutional development in historic preservation in the USA -As understood from the above mentioned literature, early attempts for preservation activities were mainly conducted by private citizens and local or nationwide associations/organizations, which all contributed to the public awareness and knowledge in the preservation field in the early 19 th century, even though most attempts failed to reach success (Jokilehto, 2011: 263). Private sector activities in the early years were mostly developed upon significant figures, events, or structures, whereas the government focused on the preservation of natural landmarks and parks and took virtually no active role in the preservation of historic buildings. Regarding "why" to preserve, patriotic reasons were more prominent than the architectural history, in preservation activities. Similarly, the older the better was the dominant thought (Tyler et al., 2009: 27-30).
In addition, according to Murtagh (1997), the assertion of legitimacy, history for reassurance, and use of preservation as defense against cultural and political hegemony were among other reasons and stimuli, and women were highly dominant figures in preservation practices. Compared to today's organized and systematic activities, the preservation movement has changed dramatically since its early years. At present, local, state, and federal government institutions work together with nonprofit organizations to support the preservation activities. With the acceptance of NHPA in 1966, significant structural changes, changes in the way of the perception of preservation, and its main actors were observable. Entire areas were designated as historic districts, recent buildings were also included in the National Register depending on their significance, and heritage tourism activities increased largely. Similarly, with the Tax Reform Act in 1976, private sector involvement in preservation activities multiplied largely thanks to the tax incentives/tax cut, which turned historic structures into financial opportunities and a part of the business, rather than obstacles for development.
Preservation of old buildings, especially adaptive reuse became an important stimulus for urban revitalization and renewal, and the Main Street Program of the 1980s promoted this effort. All these perspectives also encouraged and increased the number of preservation activists and advocates (Tyler et al., 2009: 53-55, 60).

cross-cultural coMParison anD Possible knowleDGe transfer values / intercultural exchanGe of exPeriences
In this section, based on the above-mentioned descriptive part in which differences between the Turkish system and the system in the United States have been argued, together with an illustration of the links and relationship between the two countries. What follows is a suggestion of the possible intercultural exchange of experiences and knowledge between the two countries, by crossreplicating some aspects of the system. As for the differences, thanks to the Ottoman waqf system and its role in preservation in Turkey, a financial source for the repair expenses of waqf buildings is already present through their income-generating properties (called 'akar'). Even though waqf was a private enterprise when it was first established by philanthropic people, at present it is transferred onto the state institution of Directorate General of Foundations (DGF). In the USA, similarly, there are federal trusts, but different from the waqf system and DGF in Turkey. They do not have a permanent financial source and have to create their source of income when the preservation need arises, and there is not a central institution like DGF for the management and administration of federal trusts. A comparison between Turkey and the USA also reveals that the establishment of NGOs in the preservation field was much delayed in Turkey. It was in the 1990s that the private sector inclusion and the number of preservation organizations increased substantially in Turkey (Şahin-Güçhan and Kurul, 2009: 38). Yet, none of the early organizations active in historic preservation in the late 19 th -early 20 th centuries is existent today or if they are, they changed their fields of activity (Keskin, 2015: 185). Contrary to the rapidly increasing private sector involvement in the USA, civil society organizations in the preservation field in Turkey do not show such fast development. Also, NGOs have an enormous stimulus both in the development of historic preservation studies and in increasing community awareness in the USA. In the same way, Watt (1991: 247) argues that "America is a 'strong' nation with a 'weak' state (contribution)" compared to other European countries. American civil society organizations such as APT, Presidio Trust, NTHP turned into huge institutions carrying out preservation studies and giving training throughout the country. In Turkey, on the other hand, governmental involvement and revenue as a percentage of preservation activities in comparison with the private sector, are much higher than in the USA, and there is a more centralized system both in terms of regulations/jurisdictions and admin-istration of heritage foundations. However, in the USA, individual/private support is the main financial source for preservation works, and jurisdictions of preservation organizations are rather minimal (Dişli, 2013: 116-117 (Dinler, 2021). As another similarity and link between the two countries, preservation education at the university graduate level started in the same years, at the beginning of the 1960s. What is even more, the historic pres-Scientific Paper ervation program at METU in Turkey was founded with the aid of the USA, with the aim of addressing the needs of the Middle East (Dinler, 2021). However, in the USA, the preservation program is more interdisciplinary and gathers students from different departments, except in the case of architecture. At present, in addition to graduate-level historic preservation programs, universities in both countries also have four-year or two-year bachelor/minor degrees and certificate programs in heritage preservation. 9 In addition, in both countries, there are either tax deductions or inceptions in preservation activities done by private bodies, but it is not the primary stimulus for the ones in Turkey, though highly important in the USA. Similarly, both countries have their own regulations and organizations related to historic preservation that emerged in similar periods. In Turkey, it was around the mid-19 th century that the first regulations were adopted and the institutionalization of the waqf system was acknowledged. In the same way, federal involvement in the preservation field was observable in the 1860s in the USA and it was in the early 20 th century that the Antiquities Act came into force.
As for knowledge transfer values and intercultural exchange of experiences between the two long-established systems, the situation is as follows: − It is suggested to give structure to the highly developed voluntarism, citizen initiative, and private contribution in historic preservation activities in Turkey like in the United States. Preservation funds and funding institutions in the USA, as well as tax incentives programs, contain the potential knowledge transfer values for Turkey. In the same way, the waqf-based buildings in Turkey, which already have a financial source for their preservation and are tax-exempt in their repairs, together with the centralized and autonomous administration and management system for the waqf income and private preservation foundations in Turkey, make it possible to organize predetermined preservation decisions. − Although in the USA universities accept students for the historic preservation graduate programs from all disciplines in addition to architecture programs, in Turkey, most universities accept only architecture students at the graduate level. That is why the interdisciplinary nature of the USA universities has transfer value for Turkey universities. Considering that students who graduated from these programs are potential advocates of private organizations, NGOs, and community engagement in preservation practices, it is important to increase the interdisciplinary nature, quality, number, and alternatives for historic preservation degree/ certificate programs.

conclusion
The paper compared differences and similarities in state and community-based historic preservation mechanisms and policies in Turkey and the USA, with the aim of revealing possible knowledge transfer values for each other. The history and development of community engagement, namely through the waqf and NGO system, their role, and main legislation and tendencies in historic preservation in both countries were examined for a better understanding of the background and its implications in preservation practices. The role of private actors in the preservation of historic properties is particularly sensitive, both in Turkey and in the USA. Although not always in terms of financial support, they generate reactions and engender fundamental questions for the repair of historic buildings, districts and even cities. The research found that the development of preservation legislation in the USA and Turkey progressed differently. While in the USA, parks, and landscapes were the main interest of the government, movables, and museum objects were given greatest importance in the 18 th -19 th century legislations in Turkey. The private sector involvement and contribution supporting preservation activities also show differences, such that in the USA, NGOs played an important role in local, national, and federal levels since the early periods and either patriotic reasons or tax incentives increased the private sector contribution. Yet, in Turkey except for the classical waqf system, neither the financial power nor the number of NGOs was high and effective in preservation activities. Rather, it is the government that holds the majority of repairs. The main reasons for giving and volunteering were benefactions rather than financial incentives at the beginning. The 1960s-70s could be considered the time for the development of comprehensive preservation legislation in both Turkey and the USA and the concept of site/district conservation. Overall, they both proved to be effective in heritage preservation, no matter whether state-funded or privately-funded practices are dominated. In addition, both the deep-rooted waqf system of Turkey and the long-established NGO system of the USA contribute significantly to the preservation of heritage and have possible knowledge transfer values for each other. All the state institutions and NGOs/ private bodies / community involvement are equally essential actors, and beyond their individual improvements, more collaboration among them should guarantee more increased improvements in preservation works. Similarly, Bahçeci and Yenel (2019) point out the importance of a strong and mutual collaboration between the state, local municipalities, civil society organizations, and the private sector and suggest creating a common platform and a network that will enable them to easily interact with each other. That way it would be possible to provide better management and preservation of the heritage. This study similarly, suggests that the relationship between the built environments and their users/community contribution should be ensured for their management and sustainability. In the same way, the lessons learned from the comparison of Turkey and the USA, their different approaches, private sector contribution, and legislations in preservation, might have the possibility of adaptation and application in different national contexts.   Author's biography Gülşen Dişli, PhD., is an Associate Professor and Head of the Historic Preservation and Restoration Program. Her main areas of expertise are architectural conservation, historic preservation, functional systems in historic buildings, and cultural heritage management. Her scientific achievements include numerous journal papers, book chapters, and conference presentations on existing built heritage, their conservation, and management. A single author is responsible for all the contributions and writing processes of this research article.