WASHINGTON, DC — Advisory Council on Historic Preservation (ACHP) members voted on May 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 constructed on Army installations nationwide prior to 1919 and covers 867 homes located on 19 installations in 14 states. The Program Comment for Preservation of Pre-1919 Historic Army Housing, Associated Buildings and Structures, and Landscape Features goes into effect immediately.

“This program comment ensures the Army both complies with the National Historic Preservation Act and offers military families who live in historic housing the quality of life, health, and safety they require and deserve,” ACHP Chair Sara C. Bronin said. “It also provides the flexibility necessary to enable the continued use of these historic buildings.”

The Army will not have to conduct individual, case-by-case Section 106 reviews for the frequent and recurring undertakings covered by the program comment. The undertakings, identified as management actions, include maintenance; repair; rehabilitation; abatement of hazardous materials; and mothballing; as well as lease, transfer, and conveyance of housing between the Army and privatized housing partners. The program comment allows the use of modern readily available industry-standard building materials and methods in the implementation of management actions.

“We are very pleased with the outcome of the vote by the Advisory Council on Historic Preservation approving the Army’s Program Comment for Pre-1919 homes,” Honorable Rachel Jacobson, the Assistant Secretary of the Army for Installations, Energy and Environment said. “This outcome will allow us to modernize these homes to make them more livable for soldiers and families, while at the same time preserving their historic nature and significance. We are appreciative for the support of Advisory Council on Historic Preservation in the development of this constructive solution.

“Our pre-1919 historic homes have been an essential part of the Army’s history for almost 200 years and this Program Comment will assist the Army in its effort to provide quality housing, while simultaneously ensuring the preservation and continued use of some of the Army’s oldest and most significant historic buildings.”

The consideration of a program comment for pre-1919 housing began with a series of high-level meetings hosted by the Army in July and August 2023 with senior leaders from the ACHP, the Department of the Interior, and other stakeholders. The Army followed these discussions with a public comment period and six consultation meetings with key stakeholders in November and December 2023. The ACHP also engaged with State Historic Preservation Officers, Tribal Historic Preservation Officers, Indian Tribes, and Native Hawaiian organizations on the proposal and accepted public comment.

The decision to advance the program comment was informed by three program comments previously approved by the ACHP for other historic Army housing, including the Program Comment for Army Inter-War Era housing 1919-1940; the Program Comment for Army Capehart-Wherry housing 1949-1962; and the Program Comment for Army Vietnam War Era housing 1963-1975.

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.