The Department of the Army (Army) notified the ACHP that it had established a Strategic Agenda to improve the National Historic Preservation Act (NHPA) compliance process (NHPA Strategy) for Army historic properties in a letter from the Assistant Secretary of Army Installations, Energy and Environment dated July 26, 2019. Among the initiatives set forth in the NHPA Strategy was pursuing programmatic Army-wide NHPA compliance solutions with the ACHP for Army historic properties. In particular, the Army Federal Preservation Officer (FPO) was directed to achieve programmatic NHPA solutions for historic housing.

To achieve these solutions, the Army may utilize alternative procedures to comply with the requirements of the NHPA. Section 106 of the NHPA requires federal agencies to take into account the effects of their undertakings on historic properties and provide the ACHP a reasonable opportunity to comment with regard to such undertakings. The ACHP is the federal agency tasked with review of other federal agencies’ compliance with the NHPA and the implementing regulations.

Program Alternatives

The Army has a number of program alternatives to meet its NHPA Section 106 requirements such as the Army Alternate Procedures, Army Capehart Wherry Housing Program Comment, and the Army Inter-War Housing Program Comment in place to help achieve these goals. Currently, the Army is seeking a Program Comment for Army Vietnam War Era Housing (1963-1975).

Program Comment for Vietnam War Era Housing (1963-1975)

The Section 106 regulations (36 CFR Part 800) set forth the process by which federal agencies comply with NHPA requirements. Under Section 800.14(e), federal agencies may request that the ACHP issue a program comment on a particular program or category of undertakings in lieu of conducting individual reviews of each individual undertaking as in 36 CFR 800.3 through 800.7. A federal agency can meet its Section 106 responsibilities for a category of undertakings by taking into account the program comment and by following the steps set forth in those comments.

On August 26, 2022, the Army submitted a request for a Program Comment to manage its inventory of Vietnam War Era (1963-1975) historic family housing. The intent of this Program Comment is to address the Army’s NHPA compliance requirements for its nationwide inventory of more than 7,500 Vietnam War Era housing units. This program alternative will conserve time, budget, and staff resources in the management of the Army’s inventory of Vietnam War Era housing. 

For the purposes of the Program Comment, the Army acknowledges that all Vietnam War Era housing units are historic properties. This Program Comment would enable the Army to conduct a category of frequent and recurring undertakings, identified as management actions, including maintenance, repair, rehabilitation, renovation, abatement of hazardous materials, mothballing, cessation of maintenance, demolition, new construction, lease, transfer, conveyance, and the use of modern industry standard building materials. Because these actions present a potential for adverse effects to historic properties, the Army has identified treatment measures to mitigate the adverse effects of these undertakings.

Prior to the official request to the ACHP, the Army conducted extensive outreach and consultation. Information on the Army’s outreach and relevant documentation is available on the Army's website here.

Next Steps

The Army formally submitted its request for a Program Comment from the ACHP on August 26, 2022. This initiated a 45-day review period as specified in 36 CFR 800.14(e), and per agreement between the Army and the ACHP, the review period has been extended to October 26, 2022. The ACHP is soliciting input from State Historic Preservation Officers, Indian tribes, and Native Hawaiian organizations, as well as the public and will make a copy of the Program Comment available for a 14-day public review period.


Army Federal Preservation Officer Dr. David Guldenzopf  (571) 256-7822

ACHP Army Liaison Megan Borthwick  (202) 517-0221

Additional Information

Program Alternatives

Program Comments

Program Comment Questions and Answers

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