NAPC has been monitoring potential changes to the federal review process, specifically focusing on policy components that might impact outcomes at the local level. The Advisory Council on Historic Preservation (ACHP) has proposed an agency-wide Program Comment on Accessible, Climate-Resilient, Connected Communities. Program Comments are intended to provide an alternative process to standard Section 106 review. ACHP Chair Sara Bronin has offered to give a virtual presentation for NAPC members on Thursday, September 19, from 2 pm - 3 pm EST to learn more about the Program Comments and ask questions. Registration is available here: https://lnkd.in/enjjJdbh
NAPC appreciates the initiative that ACHP has taken to evaluate policies and practices in the areas of housing, clean energy, energy efficiency, and climate-friendly transportation. While the effort to streamline certain aspects of reviews is valuable, NAPC is concerned that the broad scope of the proposed changes has the potential to limit the ability of local communities to participate in the Section 106 process. Local governments use the consultation process to provide information related to historic resources, balance undertaking needs with local preservation priorities, and ensure that the impacted public has a voice in our government. For some communities, the Section 106 process is their only opportunity to participate in projects that impact local resources. Local consultation has traditionally helped identify eligible cultural resources that might otherwise be overlooked.
NAPC is also concerned that this Program Comment could create confusion between federal and local level reviews. Under the proposed Program Comment, some reviews would be limited to the building façade and the replacement of windows and doors would be exempt. However, most local commissions with design review have purview over any proposed changes to a building’s exterior, including door and window replacements. Alternately, commissions in rural areas may be less focused on design review, while placing great emphasis on protecting archaeological resources, linear resources (for instance national historic trails), and cultural/working landscapes.
Given the potential far-reaching impacts of the proposed changes, NAPC believes it is important that communities have an opportunity to inform the draft. ⭐ We want to hear from you! NAPC invites you to participate in the public comment period and discuss how this Program Comment will impact preservation at the local level. The public comment period is open until October 9th and additional information can be found here: https://lnkd.in/e98_f6MU
The Advisory Council on Historic Preservation is an independent federal agency comprised of 24 statutorily designated members from federal agencies, preservation organizations, Indian tribes, and expert private citizens. NAPC serves as an appointed Observer on the ACHP.