WASHINGTON, DC — The Advisory Council on Historic Preservation (ACHP) voted on March 17 to approve the issuance of a Program Comment that provides the Department of the Army with an alternate way to comply with its responsibilities under Section 106 of the National Historic Preservation Act (NHPA). This Program Comment specifically addresses the Army’s inventory of housing, associated buildings and structures, and landscape features constructed on Army installations nationwide during the Vietnam War period from 1963-1975. The Program Comment goes into effect immediately.

The Program Comment covers approximately 7,800 Army Vietnam War-era housing units and the associated buildings and structures, and landscape features built on Army installations between 1963 and 1975. Management actions would fall under the Program Comment, 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 and methods.

The Army regards all Vietnam War Era housing as historic properties and acknowledges that these actions present a potential for adverse effects to them. For most undertakings covered by the Program Comment, the Army will not have to go through individual, case-by-case Section 106 reviews, but will follow procedures for decision making and materials selection included in the Program Comment.

The Program Comment identifies more than 500 Properties of Particular Importance that best convey the properties’ association with the buildup for the Vietnam War and provides for a review process in the event that these properties are proposed for demolition.

ACHP Chair Sara C. Bronin said the ACHP works with all federal agencies to ensure they meet their obligations under the NHPA.

“ACHP members support the Army’s intent to streamline the Section 106 review process while protecting and maintaining this type of historic housing, ensuring it can continue to serve our nation’s soldiers and their families,” Bronin said. “The Army undertook a year-long effort to develop this Program Comment and address the input it received. The ACHP facilitated consultation sessions with states, Indian tribes, Native Hawaiian organizations, and preservation organizations in recent months to ensure everyone had input during this process, and I worked directly with the Army, ACHP members, and staff to ensure the Program Comment balanced several priorities.” 

To mitigate the effects, the Army will prepare neighborhood design guidelines, conduct in-depth professional research, and prepare nationwide Army Vietnam War Era housing historic context information. This research and documentation will result in public education. Privatized housing partners will be educated about the applicability of tax credit programs. An annual report and meeting will address any significant issues that arise while implementing the Program Comment, how these issues were addressed, and how they may be avoided in the future.

A Program Comment is one among a number of administrative tools the ACHP can use to provide greater flexibility and tailored approaches for federal agencies as they work to ensure historic preservation interests are balanced with development needs.

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