Army Historic Preservation and Cultural Resources Management

Program Comments are an alternate method of National Historic Preservation Act (NHPA) Section 106 compliance that allow Federal agencies to tailor Section 106 to meet agency-specific needs.  Program Comments provide the Advisory Council on Historic Preservation (ACHP) the flexibility to allow Federal agencies to comply with NHPA Section 106 by means of a single compliance action for a category of undertakings and large class of property types, rather than addressing each undertaking for each property separately under project-by-project review procedures in 36 CFR 800.  This is especially valuable to Federal agencies like the Department of the Army who have repetitive management actions for very large inventories of similar property types.  Once issued by the ACHP, Army and Department of Defense (DoD) Program Comments satisfy and complete NHPA compliance for the entire class of property types and categories of undertakings.  The Army and DoD have a series of Program Comments, and a Programmatic Memorandum of Agreement, pertaining to various classes of historic property types and categories of undertakings:

Program Comment for Preservation of Pre-1919 Historic Army Housing, Associated Buildings and Structures, and Landscape Features. This Program Comment was issued by the ACHP in May 2024. It addresses NHPA compliance for the Army’s inventory of housing, associated buildings and structures, and landscape features constructed before 1919. The Program Comment provides Army-wide NHPA compliance for the category of undertaking termed management actions defined as: repair, rehabilitation, abatement of hazardous materials, mothballing, lease, transfer, and conveyance. The Program Comment applies to all Pre-1919 Army housing including housing designated as a National Historic Landmark (NHL) or contributing to a NHL. The Program Comment supports full implementation of scopes of work for maintenance, repairs, and improvements to NHL housing by ensuring that the full range of appropriate and cost-effective building materials are considered through a systematic approach and standardized methodology.

Program Comment for Preservation of Pre-1919 Historic Army Housing, Associated Buildings and Structures, and Landscape Features

Program Comment for Department of the Army Vietnam War Era Historic Housing, Associated Buildings and Structures, and Landscape Features (1963–1975). Issued by the ACHP in March 2023, this Program Comment concludes NHPA addresses all Army housing, associated structures, and landscape features dating from 1963-1975.  This category of Modern Housing appears in various architectural styles including Ranch, Split-Level, and Contemporary designs. While single family homes and duplexes were built, townhouse and apartment construction predominated during this period.  The Program Comment provides Army-wide NHPA compliance for the following management actions: 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 in the implementation of management actions. The Program Comment is in effect through 2055.

Program Comment for Department of the Army Capehart and Wherry Era Army Family Housing, Associated Structures, and Landscape Features (1949-1962).  This Program Comment was issued by the ACHP in 2002.  It addresses NHPA compliance for the Army’s inventory of housing, associated structures, and landscape features dating from 1949-1962.  The Program Comment provides Army-wide NHPA compliance for the category of undertaking termed management actions defined as: maintenance and repair, rehabilitation, layaway and mothballing, renovation, demolition, demolition and replacement, and transfer, sale or lease for all subject properties.  This Program Comment is currently in effect and has no expiration date.

Program Comment for Department of the Army Inter War Era Historic Housing, Associated Structures, and Landscape Features (1919-1940).  This Program Comment was issued by the ACHP in 2020.  It addresses NHPA compliance for the Army’s inventory of housing, associated buildings and structures, and landscape features dating from 1919-1940.  The Program Comment provides Army-wide NHPA compliance for the category of undertaking termed management actions defined as: maintenance, repair, rehabilitation, renovation, abatement, mothballing, demolition, replacement construction, new construction, lease and conveyance.  The Program Comment does not apply to housing designated by the Secretary of the Interior, National Park Service as a National Historic Landmark (NHL) or contributing to a NHL or to Inter-War Era housing at Fort Meade, MD.  This Program Comment is currently in effect and will expire in 2055.  For more information on this Program Comment, see https://www.denix.osd.mil/army-pchh/.

Program Comment for Department of Defense World War II and Cold War Era Ammunition Storage Facilities.  This Program Comment was issued by the ACHP in 2006.  It addresses NHPA compliance for all DOD World War II and Cold War Era Ammunition Storage Facilities dating from 1939-1974.  The Program Comment provides NHPA compliance Army-wide for ongoing operations, maintenance and repair, rehabilitation, renovation, mothballing, cessation of maintenance, new construction, demolition, deconstruction and salvage, remediation activities, and transfer, sale, lease, and closure of all such ammunition storage facilities.  The Program Comment includes all ammunition storage facilities in historic districts comprised solely of ammunition storage facilities, and excludes ammunition storage facilities that are part of larger historic districts that contain other types of properties (such as housing).  This Program Comment is currently in effect and has no expiration date.

Program Comment for Department of Defense Cold War Era Unaccompanied Personnel Housing (UPH).  This Program Comment was issued by the Advisory Council on Historic Preservation in 2006.  It addresses NHPA compliance for all buildings and structures built between 1946-1974 designed as UPH, regardless of current use, as well as associated buildings and structures to support UPH, such as dining halls and laundry facilities, that may be historically significant.  The Program Comment provides NHPA compliance Army-wide for ongoing operations, maintenance and repair, rehabilitation, renovation, mothballing, cessation of maintenance, new construction, demolition, deconstruction and salvage, remediation activities, and transfer, sale, lease, and closure of such facilities. The Program Comment excludes UPH that are contributing elements to National Register of Historic Places listed or eligible historic districts not comprised solely of UPH and associated buildings and structures.  This Program Comment is currently in effect and has no expiration date.

Program Comment for Army Ammunition Production Facilities.  This Program Comment was issued by the ACHP in 2006.  It addresses NHPA compliance for the Army’s WWII and Cold War Era Army Ammunition Production Facilities and Plants dating from 1939-1974.  The Program Comment provides NHPA compliance Army-wide for ongoing operations, maintenance and repair, rehabilitation, renovation, mothballing, cessation of maintenance, new construction, demolition, deconstruction and salvage, remediation activities, and transfer, sale, lease, and closure of all such facilities.  The Program Comment applies to all buildings and structures in historic districts comprised solely of ammunition production facilities, and excludes ammunition production facilities and plants that are part of larger historic districts that contain other types of properties.  This Program Comment is currently in effect and has no expiration date.

Programmatic Memorandum of Agreement (PMOA) for DOD World War II Temporary Buildings.  This PMOA was signed by the ACHP in 1986 and amended in 1991.  It is similar to a Program Comment in that it addresses NHPA compliance for demolition of all Army and DOD temporary buildings constructed between 1939 and 1946.  The PMOA provides NHPA compliance Army-wide for the demolition of World War II era temporary buildings.  The PMOA is currently in effect and has no expiration date.  PMOAs were used prior to the ACHP including Program Comments in 36 CFR 800.

Army Alternate Procedures for Historic Preservation. The AAP is for those advanced Cultural Resource Managers (CRM) at Army installations with mature historic preservation programs.  The AAP provides those advanced practitioners with a more powerful and highly streamlined NHPA compliance procedure than is available through standard NHPA Section 106 PAs or MOAs.  The AAP is the next level for Army CRMs, allowing them the opportunity to significantly improve and enhance their support to the Army’s national defense mission.  

The Army Alternate Procedures for Historic Preservation (AAP) is an optional regulatory procedure that Army installations may choose to adopt to satisfy compliance with NHPA Section 106, in lieu of the ACHP’s regulations at 36 CFR Part 800.  The regulatory provision at 36 CFR 800.14(a) provides Federal agencies the authority to develop their own internal procedures to implement Section 106 and substitute them for 36 CFR 800, as long as they are consistent with the ACHP’s Section 106 regulations.  The Army developed the AAP and the ACHP adopted those procedures in 2001.  The AAP was subsequently amended by the ACHP and republished in 2004.