ACRA has provided comments to the Advisory Council on Historic Preservation (ACHP) on their revised program comment on housing and transportation.
The Program Comment draft followed the Council’s release last summer of its controversial Proposed Program Comment on Accessible, Climate-Resilient, Connected Communities. That proposal was intended to “accelerate the review of federal agency actions to rehabilitate existing housing or create new housing in existing buildings, to maintain and update buildings and their immediate environs in response to climate concerns, and to rehabilitate or create new climate-friendly transportation infrastructure. It would apply to all agencies proposing to carry out, license, permit, or fund the covered undertakings which elect to use it.”
The initial Program Comment draft elicited 144 written comments from the preservation community and others, including from ACRA, and prompted the Council to release the revised Program Comment draft last month.
In its comment letter on the revised draft, ACRA states:
Although ACRA commends the Council for its good-faith efforts to address a number of concerns with the Program Comment, it continues to believe that the scope of this proposed Program Comment is so broad and comprehensive that it will lead to a raft of unintended consequences that will impair the ability to preserve, protect and mitigate from harm our nation’s cultural heritage. Worse, if adopted the Program Comment will set a precedent that may be abused by subsequent Councils and Council Chairs.
For these reasons, ACRA continues to recommend that the Council withdraw the Program Comment and work with individual agencies and other stakeholders to develop programmatic agreements appropriate to reach agency’s unique mission, culture and program.
The Council has not indicated its next steps on the Program Comment. Stay tuned to ACRASphere for updates as they happen.