This week NCSHPO and the National Trust for Historic Preservation (NTHP) submitted joint final comments on the Army’s proposed Program Comment concerning pre-1919 Historic Army Housing.

In submission of these comments, NCSHPO & NTHP recognize the minor tweaks made by the ACHP in response to earlier comments made by stakeholders inclusive of NTHP and NCSHPO. Together, the National Trust and NCSHPO expressed in these final comments continued opposition. Due in no small part to the fact that 74% of the historic properties to which it applies are National Historic Landmarks, and the proposed Program Comment falls short of the higher standard of care required under Section 110(f).

“As both of our organizations have previously stated, we are opposed to the ACHP’s adoption of this Program Comment unless all National Historic Landmark (“NHL”) properties are removed from its scope.”

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This latest correspondence piggybacks on the standalone comments submitted by NCSHPO last week to ACHP expressing concern with the Army’s Proposed Program Comment Plan for the Preservation of Pre-1919 Army Housing and associated elements. These comments reiterate observations made throughout the consultation process including that under the program comment: NHL’s do not seem to receive a higher standard of care as required, SHPOs will lose ability to consult on matters they deem important (to include the use of appropriate materials, which would in turn afford the Army a large amount of discretion).

In conclusion, Executive Director Erik Hein noted “we believe the passage of yet another Program Comment over serious objections raised by SHPOs and other Council members is a bad precedent. While it may provide some short-term appearance of relief, it will not only undermine the entire Section 106 process, it will continue to erode confidence and trust in the Advisory Council and have more wide-reaching effects…”.