Read the full text of the VA Program Comment in the Federal Register.


On October 26, 2018, the Advisory Council on Historic Preservation (ACHP) issued a "Program Comment for Vacant and Underutilized Properties" at the request of the U.S. Department of Veterans Affairs (VA). The VA Program Comment enables VA to proceed with certain undertakings following an expedited Section 106 review process that complements VA’s real property priorities in finding uses for its vacant and underutilized properties. The VA Program Comment is designed to reduce vacant and underutilized properties in VA's real property portfolio and allow VA to redirect limited operations and maintenance staff and funding to those facilities supporting delivery of services and benefits to veterans. The VA Program Comment will remain in effect until October 26, 2028.

What is a Program Comment?

A Program Comment is an alternative process a federal agency may use to comply with the requirements of Section 106 of the National Historic Preservation Act (NHPA). Section 106 requires federal agencies to take into account the effects of their undertakings on historic properties and provide the ACHP a reasonable opportunity to comment on such undertakings. The ACHP is the federal agency tasked with overseeing the Section 106 review process and issuing implementing regulationsThe Section 106 regulations (36 CFR 800) set forth the process by which federal agencies comply with NHPA requirements. Under 800.14(e), federal agencies may request the ACHP provide a Program Comment on a particular program and category of undertakings in lieu of conducting individual reviews of each undertaking as set forth in 36 CFR 800.3 through 800.7.

VA Program Comment Mitigation

The VA Program Comment (Section 6) requires the agency to develop a public benefit document based on existing literature in archives, available VA documentation, photographs, and other source material. This programmatic mitigation is meant to emphasize the cultural geography of VA over time as a study of the relationship between VA culture and place. A draft of the resulting report “A Cultural Geography of the VA Built Environment” was provided to the National Conference of State Historic Preservation Officers (NCSHPO), the National Association of Tribal Historic Preservation Officers (NATHPO), the ACHP, and other consulting parties for review on August 1, 2023. A final version was submitted to the ACHP and made available to the public on October 11, 2023. To download the report, click the link above or visit the VA Historic Preservation Office website.

VA Program Comment Implementation - Current Status

The annual period for review of the VA real property portfolio has closed for 2024. During the 30-day review period (May 6 - June 5, 2024), interested parties provided the VA Federal Preservation Officer (FPO) with requests for additional information, comments, and objections concerning the properties on the 2024 list of 329 vacant and underutilized properties.  
The agency is currently reviewing and responding to these submissions. Once questions, comments, and objections regarding properties on the list are resolved, VA may proceed with utilizing the Program Comment for applicable undertakings. The steps for using the Program Comment begin with VA facility staff filling out the VA Program Comment Project Form and submitting it to the FPO for approval. Once approved by the FPO, VA staff can follow the relevant steps detailed in the Program Comment based on the type of property (i.e. historic vs. non-historic and utilitarian vs. non-utilitarian).

Please direct all correspondence regarding the Program Comment to the FPO Héctor M. Abreu-Cintrón via email at

Annual Lists, Narratives, and Summaries

Associated VA Materials

Contact for Further Information

For further information, please contact the VA's Federal Preservation Officer (FPO).

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