ACRA has submitted comments to the ACHP about its proposed Section 106 exemption for federal agencies that install electric vehicle supply equipment (EVSE).

The ACHP has proposed this exemption because they believe that installation of EVSE is likely to result in minimal or no effects to historic properties when certain conditions are met. In its June 4 comment letter (link), ACRA said that, while it does not oppose the exemption, the proposal raises a number of questions it hopes the Council will address before issuing a final exemption. These questions revolve around a number of issues, including how the exemption addresses inadvertent discoveries, ensuring that relevant agencies base exemption decisions on the full panoply of cultural resource management disciplines, in addition to archaeology, and ensuring that federal agencies properly assess sites absent a formal Section 106 process.

Read the ACRA letter here.