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 Implementation - Current Status

The annual period for review of VA's real property portfolio has closed for 2022. During the 30-day review period (July 25-August 26, 2022), interested parties provided VA's Federal Preservation Officer (FPO) with requests for additional information, comments, and objections concerning the properties on the 2022 list of 335 vacant and underutilized properties.

VA 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 VA's FPO for approval. Once approved by the FPO, VA can then 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).

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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