ACHP recently announced interest in pursuing (4) Program Comments based on two policy statements enacted in 2023. In both the Policy Statement on Housing and Historic Preservation and the Policy Statement on Climate Change and Historic Preservation, the ACHP suggested the Section 106 review process could be improved to enable federal agencies to more effectively advance historic preservation while also meeting the nation’s housing needs and climate goals.

While normally a Program Comment is requested by a federal agency, ACHP is able to issue their own though the way in which it is being done is unprecedented. In many instances, NCSHPO deems Program Comments appropriate & useful, but has reservations over the broad use of Program Comments, and their use to essentially eliminate SHPO and stakeholder consultation. 

NCSHPO is participating in listening sessions hosted by the ACHP, which afford stakeholders the opportunity to provide feedback on Climate-Friendly Transportation, Housing, and Clean Energy. Read more on this initiative from the ACHP.

NCSHPO has submitted a letter in response to ACHPs effort.