The public review period is now open on the proposed Army Program Comment for Vietnam War Era Historic Housing, Associated Buildings and Structures, and Landscape Features. The text of the proposed Program Comment, along with information on how to provide comments, can be accessed through ACHP’s Army Program Comment Website.

Those interested in commenting on the proposed Program Comment may do so by submitting written comments, so they are received by the ACHP on or before Friday September 30, 2022. The ACHP will consider these comments as it works to respond to the Army’s request in accordance with the provisions of 800.14(e). Please send your comments to

On August 26, 2022, the ACHP received a formal request from the Department of Army to issue a Program Comment for Vietnam War Era (1963-1975) Historic Housing. The Army and the ACHP have agreed to extend the 45-day period for ACHP action to a 60-day period ending on October 26, 2022.

A Program Comment is an alternative process available to federal agencies to assist them in complying 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 regulations at 36 CFR part 800. Under Section 800.14(e), federal agencies may request that the ACHP comment on a particular program or category of undertakings in lieu of conducting individual reviews of each undertaking as set forth in 36 CFR parts 800.3. through 800.7. A federal agency can meet its Section 106 responsibilities for a category of undertakings by taking into account the ACHP’s Program Comment and by following the steps set forth in those comments.

The intent of this Program Comment is to address the Army’s Section 106 compliance requirements for its nation-wide inventory of over 7,500 Vietnam War Era housing units located on Army installations nationwide in a manner that balances historic preservation requirements with its responsibility to provide the thousands of military families who live in this historic housing with the quality of life, health, and safety they require and deserve. For the purposes of the Program Comment, the Army acknowledges that all Vietnam War Era housing units are historic properties. The 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 readily available industry standard building materials and methods in the implementation of management actions. 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.  This proposed Program Comment reflects input the ACHP provided to the Army and incorporates feedback provided to the Army during its own public and consulting party participation period, which occurred from November 2021 to June 2022.

Upon receiving a formal request for a Program Comment, the ACHP is responsible for consultation with State Historic Preservation Officers (SHPOs) and Tribal Historic Preservation Officers (THPOs), Indian tribes, and Native Hawaiian Organizations (NHOs). Through this notification, the ACHP is seeking the views of the general public on the proposed Program Comment.

Should you have any questions or require additional assistance, please contact the ACHP’s Army Liaison, Megan Borthwick, at (202) 517-0221 or

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