In 2018, the "Programmatic Agreement By and Among The U.S. Army Corps of Engineers, U.S. Bureau of Land Management, Advisory Council on Historic Preservation, Alaska State Historic Preservation Officer, Alaska Department of Natural Resources, and Donlin Gold, LLC Regarding the Donlin Gold Project" was executed; the PA was first amended in 2019. In accordance with Stipulation XV, the signatories are considering a second amendment to add a new stipulation regarding undertakings not subject to further Section 106 review to include activities that involve less than one square meter, routine trail maintenance, routine road maintenance, and heavy maintenance, reconstruction, or replacement of existing facilities in previously inventoried areas, provided that the facility has been determined not eligible for listing on the National Register of Historic Places.