ACRA has urged the U.S. Army to extend the comment period for its recently released Program Comment Plan (APCP) for Army Warfighting Readiness and Associated Buildings, Structures, and Landscapes to ensure that it addresses concerns over its scope, adverse effects and other issues.
The Army stated in the APCP that it will requesting a program comment from the Advisory Council on Historic Preservation (ACHP) in order to “urgently streamline its compliance with Section 106 of the National Historic Preservation Act (NHPA) and 36 CFR Part 800.” According to the Army, the program comment is needed to “facilitate the rapid transformation and modernization of the Army, a process vital to maintaining warfighting readiness and national security.”
The program comment would cover all Army warfighting readiness activities, which it defines as military training, testing, equipping, and industrial activities, and management actions for modernization of all buildings, structures, and landscapes associated with those activities. In all, the program comment would include 122,000 buildings and structures that are currently 45 years of age and older, including nearly 10,000 pre-1941 buildings and structures.
Noting that this number of covered structures would dwarf those of other Army program comments, ACRA stated in its response letter that “the extremely broad scope of this APCP, combined with the short timeframe in which interested parties can comment, could lead to inadvertent and unforeseen effects that fail to strike that right balance. ACRA believes it is critical for the Army to get this Program Comment right the first time in order to avoid irreversible damage to our cultural heritage in the future.”
ACRA also raised concerns about provisions in the APCP that would include adverse effects like cessation of maintenance and demolition under the program comment, replace Section 106 procedures with those under NEPA, and fail to require Army installations to seek traditional knowledge from Tribal representatives, Tribal Historic Preservation Officers (THPOs), and Native Hawaiian Organizations. ACRA also expressed concern that the program comment would place more responsibility on Army personnel at a time when federal reductions in force and voluntary retirements are reducing staff capacity.
In the letter, ACRA offers its support to working with the Army to create “comments that empower the Army to maintain its high level of combat-readiness while complying with the NHPA and ensuring that we continue to preserve our Nation’s history.”