In 2021, the ACHP’s Program Comment Review Panel made recommendations on steps the ACHP should take to assist federal agencies in the development of program comments. The recommendations included measures about encouraging federal agencies to develop a goal statement and explanation of need for a program comment as the first step in the development process. A goal statement could explain the anticipated benefits to the agency and the likely effects on historic properties. It could also be used to introduce the agency’s goals and proposed program alternative approach to stakeholders.

While the panel’s recommendations focused on program comments, developing a goal statement can be a useful exercise for an agency’s consideration of any program alternative that might improve its preservation approach under the requirements of Section 106 of the NHPA. The ACHP offers the following questions as a guide for consideration of an agency’s program alternative goals and needs.

1. What are the federal agency’s goals in seeking a program comment [or other program alternative]?
2. What is the category of undertakings?
3. What metrics are available to quantify the magnitude of the category of undertakings (e.g., number of undertakings, frequency of their proposal, number of historic properties affected, workload statistics, etc.)?
4. Identify the part(s) of the standard Section 106 process the federal agency wants to tailor and explain why such modifications are desired.
5. What is the advantage of using a program comment [or other program alternative] for this category of undertakings in lieu of conducting individual reviews under 36 CFR §§800.4 – 800.7? What are the anticipated benefits?
6. Has the agency considered other program alternatives that could address this need? If so, why is the program comment [or other approach in §800.14 (a)-(e)] the appropriate vehicle?
7. Specify the likely effects on historic properties that would result from undertakings to be subject to the program comment.
8. Specify the steps the agency official anticipates it will take to ensure that the effects are taken into account and any anticipated preservation benefits from this approach.
9. Identify the time period for which the program comment will be requested, and why.
10. Detail any anticipated public or stakeholder interest and how the agency official plans to arrange for public participation appropriate to the subject matter and the scope of the category and in accordance with subpart A of 36 CFR Part 800.