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U.S. Army Historic Preservation Program

Privatization of Army Lodging

Parade ground, Historic Fort Benning, GeorgiaThe United States Army is currently undergoing a significant privatization effort of lodging facilities throughout the continental United States.  This privatization effort has already occurred at 21 installations in two previous phases.  The third phase consists of 21 additional installations in 13 states and is the subject of a new prototype Programmatic Agreement (PA).

For the previous phases, a time consuming effort was undertaken to create individual PAs for each installation. The prototype PA for the third phase provides a tool that can assist in the cultural resource management of an Army installation’s historic properties associated with the privatization of Army lodging. Most importantly, the Prototype PA provides a streamlined approach to the process of developing, negotiating and implementing PAs for the installations that have historic properties impacted by this privatization effort. The prototype PA will create efficiencies by providing standardized language that will be used to create subsequent PA’s for the remaining 21 installations that will take part in the privatization of lodging.

Former parade ground, now a parking lot for new housing - Fort Benning, GeorgiaA Prototype PA provides for consistency and predictability in cost, time, and outcomes, as well as the flexibility to address specific situations and conditions on each installation. As a result of agreement reached on the Prototype PA, following consultation on its development, subsequent consultation to develop installation-specific agreements for lodging privatization should be less rigorous and more efficient. The installation can, after appropriate consultation with stakeholders, include language in the subsequent agreements that address similar actions in multiple geographical areas.

Archeological investigations may be necessary if there is significant ground disturbance in previously undisturbed areas and would be considered during the consultation for each installation’s PA for the Privatization of Army Lodging (PAL) program. Cultural landscapes and/or view sheds that are impacted by any new construction will have to be taken into consideration during the consultation for each installation’s PA for the lodging privatization program.

The Army conducted multiple meetings with an internal Army working group. This group was comprised of Cultural Resource Managers from Army installations, staff members of the Army Environmental Command, and other parties within the Army historic preservation community. In addition, there have been meetings with State Historic Preservation Offices, Tribal Historic Preservation Officers, the National Conference of State Historic Preservation Officers, the National Park Service, and the National Trust for Historic Preservation, federally recognized Indian tribes and ACHP staff.  The Army prototype was approved on April 5, 2012.

Army Interiors Prototype Programmatic Agreement

Barracks at a Hawaii installationThe Department of the Army has, in concert with the ACHP, developed a Prototype Programmatic Agreement (PA) for the interiors of contributing buildings and individually eligible buildings pursuant to 36 CFR 800.14(e). The Army has more than 20,000 buildings considered eligible for the National Register in its inventory. There are many examples of interiors within the Army inventory that have been altered to the extent that they no longer contribute to the significance of the building or structure or were never considered contributing to the building’s or a historic district’s significance. Over the past year, a number of Army initiatives and Executive Orders have been implemented that require installations to improve the energy efficiency and environmental sustainability of their facilities. These initiatives have the potential to impact interiors of eligible buildings; therefore a programmatic approach was needed to assist in the protection of historic interiors while also assisting in the implementation of sustainability guidance.

The Army determined that a Prototype PA would provide Cultural Resource Managers at Army installations an additional tool to use in meeting their responsibilities under Section 106 for these federal facilities, and to streamline the consideration of these interiors. The Army proposed an approach that would relieve an installation from having to consider effects of undertakings on building interiors that have been deemed to be non-contributing or retain no character defining features. In order to facilitate the adequate assessment of the integrity of an interior or whether the interior is contributing to the significance of the building, an interiors survey format that is appropriate to this task has been developed as part of this Prototype PA. This survey streamlines the process of Section 106 review for undertakings that may affect non-contributing interiors. If the procedures in the Prototype PA are followed by the installation, no case-by-case review by the State Historic Preservation Officer (SHPO) would be required for those aspects of undertakings that may affect interiors that have been deemed to be non-contributing.

Outreach to Consulting Parties
The Army conducted multiple meetings with an internal Army working group that consists of multiple participants from throughout the United States. This group was made up of Cultural Resource Managers from Army installations, staff members of the Army Environmental Command, Army National Guard Cultural Resource practitioners, and other parties within the Army historic preservation community. In addition, there have been numerous meetings with the National Park Service, National Conference of State Historic Preservation Officers, National Trust for Historic Preservation, and ACHP staff.

William T. Sherman’s House at Fort LeavenworthCurrent Status
The ACHP issued the Prototype PA on July 19, 2011. The Army is now authorized to convey this Prototype PA to its installations. These agreements can be negotiated between an installation and a SHPO without the involvement or approval of the ACHP. Several installations have already expressed interest in doing so.

Next Steps
Given the designation of two Prototype PAs for the Department of Energy’s weatherization programs and Army Interiors, as well as current plans underway to develop additional Prototype PAs for the Federal Emergency Management Agency and the Natural Resources Conservation Service, it is clear that agencies find Prototype PAs to be useful tools for addressing certain preservation programs. In recognition of this expanding interest, ACHP staff has begun efforts to develop guidance on the process of developing Prototype PAs in order to address this expanding interest and guide agencies on those steps necessary to develop and implement such an agreement pursuant to the Section 106 regulations. Staff will share its vision for this guidance and seek committee input on its development.

Army Cultural Resource Management Program: Policy and Regulations

The Army is dedicated to pursuing innovative policies, programs, and initiatives to improve cultural resources management. Responsibility for cultural resources management at the Army headquarters level resides in two offices: the Office of the Assistant Chief of Staff for Installation Management’s Installation Support Directorate – Environment (ISE), and the US Army Environmental Command (USAEC).   ISE is responsible for promulgating cultural resources policy and guidance, while USAEC is the center for technical expertise. Most Army installations also have qualified cultural resources personnel on staff.

The Department of the Army's official policy for management, care, and preservation of cultural resources can be found in Environmental Protection and Enhancement (AR 200-1). AR 200-1 establishes broad preservation and operational policies for the Army by addressing the requirements of all major cultural resources laws, regulations, Executive Orders, and Presidential memoranda. In reference to 36 CFR Part 800, AR 200-1 establishes internal Army policy for compliance with ACHP's regulations and is not designed to replace the Section 106 compliance procedures set forth in 36 CFR Part 800.

Recently, the Army has emphasized the need for integrated cultural resources management—this is a "cultural landscape" approach to planning and management, whereby the military installation is viewed as an integrated landscape of natural and cultural resources and processes including military operations. Rather than a strictly compliance-driven approach to cultural resource management, the Army is moving towards a comprehensive integrated planning concept.

For more information about the Army's technical documents and resources, refer to USAEC's Cultural Resources Management Program Web site.

Interagency Agreement Between the Army and ACHP

In March 1996, ACHP entered into an interagency agreement (IAG) with USAEC to provide technical expertise and support in implementing the Army's cultural resources management program. This partnership assists the Army in developing efficient and effective means to manage cultural resources on its lands. Under this arrangement, ACHP assigns one or more Liaisons to USAEC to implement the agreement and to serve as subject matter experts on historic preservation issues.

The ACHP and USAEC work cooperatively to enhance the state of cultural resources management on Army lands, particularly through the development of programmatic methods of compliance with the ACHP’s regulations at 36 CFR 800.  The more notable accomplishments of the partnership include the Army Alternate Procedures and the Program Comments for four categories of World War II and Cold War era buildings.

Army Alternate Procedures to 36 CFR 800

Download the amended Army Alternate Procedures (in pdf format; 12 pp.)


On July 13, 2001, the Advisory Council on Historic Preservation approved the Army's alternate procedures, established under 36 CFR 800.14(b), the culmination of years of cooperative effort between the ACHP and Army.  The Army Alternate Procedures (AAP) allow installations to work with consulting parties to develop a streamlined plan for its Section 106 compliance responsibilities.

The Alternate Procedure Process

The Army Alternate Procedures are designed to accomplish the following goals:

  • Provide for more efficient, consistent, and comprehensive Army compliance with the goals and mandates of Section 106;
  • Encourage more thoughtful consideration and planning for historic properties;
  • Support the Army's ability to accomplish the critical mission of training soldiers for defense of the Nation; and
  • Establish a proactive planning and management based approach to historic preservation and compliance to stand in place of the formal case-by-case review process prescribed in 36 CFR Part 800(B).

Installations may choose either to continue to follow ACHP's regulations in the implementation of installation undertakings or to follow the Army Alternate Procedures. Installations that follow the Army Alternate Procedures will prepare a Historic Properties Component, based on the installation's Integrated Cultural Resource Management Plan (ICRMP) in consultation with State Historic Preservation Officers (SHPOs), Tribal Historic Preservation Officers (THPOs), Indian tribes, and other stakeholders.

The Historic Properties Component (HPC) addresses standard operating procedures for the identification, evaluation, assessment of effects, treatment, and management of historic properties, including those of traditional religious and cultural importance to federally recognized Indian tribes or Native Hawaiian organizations. The HPC also includes standard operating procedures for annual review and monitoring of installation undertakings with consulting parties to include the SHPO/THPO, federally recognized Indian tribes, and Native Hawaiian organizations.

ACHP certifies installations that have completed the HPC and have met the certification criteria. Upon certification, the installation is free to implement its actions in accordance with the agreed-upon standard operating procedures for five years without further SHPO, THPO or ACHP project-by-project review. The Army Alternate Procedures provide a process for amendments and recertification of the Historic Properties Component. Furthermore, the procedures include provisions for ACHP review of Army programs and installation compliance, and for ACHP assistance in improving Army program efficiency.

Army Alternate Procedures Contacts

Questions concerning the Army's Alternate Procedures or their implementation may be directed to the ACHP (see contact information below).  You may also consult USAEC’s AAP web page.

Program Comments on World War II and Cold War era Properties

Another programmatic approach on which the ACHP and Army worked very closely together was the development of program comments.  Program comments fulfill the Section 106 compliance responsibilities for a category of undertakings; more information can be found here. The Army has sought Program Comments to address the massive compliance challenge presented by the buildings and structures constructed during World War II and the Cold War.  Many of these buildings are currently subject to NHPA, and tens of thousands more will reach the 50-year mark within the next twenty years.   Without a programmatic compliance action like the Program Comments, this would put an enormous strain on installations as they seek to meet their regulatory requirements.

Capehart and Wherry era (1949-62) Army Family Housing, Associated Structures, and Landscape Features

The first program comment developed was for Army housing built under the Capehart and Wherry Acts to meet the unprecedented need for family housing during the early Cold War.  Issued in 2002, the Program Comment covered Section 106 compliance requirements for more than 19,000 Army family housing buildings built between 1949 and 1962.  Installations may renovate, mothball, demolish, or transfer the buildings from Federal ownership without further Section 106 review for effects to those properties.  The Program Comment does not cover other historic buildings or archeological sites affected by undertakings to Capehart and Wherry era buildings.

Treatment measures required by the Program Comment include a historic context, Neighborhood Design Guidelines, and video documentation. The context identified potential properties of particular importance, which were then used as the focus of the video documentation.

The historic context and Neighborhood Design Guidelines were completed in June 2003. Distribution of the final versions of both the design guidelines and historic context is limited to U.S. government agencies.

Program Comments for Cold War Unaccompanied Personnel Housing, and World War II and Cold War era Ammunition Storage and Production Facilities and Army Ammunition Plants

The ACHP issued three more program comments in 2006; two, covering unaccompanied personnel housing (barracks) and ammunition storage facilities, were issued to all of the Department of Defense, while one, for ammunition production facilities and Army Ammunition Plants, was issued to the Army alone.  These program comments fulfilled Section 106 compliance requirements for an additional 35,000 Army buildings.

The Program Comments require the Army to conduct several treatment measures, including:

  • a publicly available version of the historic context Unaccompanied Personnel Housing during the Cold War (1946-89)
  • historic contexts on Cold War era Ammunition Storage and Production
  • a display and popular publication on the ammunition process
  • documentation of representative property types at 11 installations

Covering both production and storage facilities for ammunition gave the Army an opportunity to examine the interaction of the property types, and similarities between their construction and operation.  As a result, the Army developed a popular publication on the World War II ammunition production process, paying particular attention to the social history of the plants and manufacturing.

Further information on the three Program Comments can be found on the USAEC website here.

Federal Preservation Officer

View FPO Contact Information

Agency and Related Links

Department of the Army:

U.S. Army Environmental Center:

Cultural Resources Management Program, U.S. Army Environmental Command:

ACHP Contact for Policy and Program Issues

Office of Federal Agency Programs
Telephone: 202-606-8505

Updated July 24, 2014

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