ACHP 2021 Section 3 Report to the President

The importance of digital tools and online access to data about historic properties was placed in sharp relief with the onset of the COVID-19 pandemic, which led to a shift to telework and took many consultation processes online. The ACHP expanded the use of its e106 Documentation Submittal System and processed all correspondence in electronic format. The ACHP also responded to questions from federal agencies, states, Indian tribes, and other stakeholders about how to navigate new challenges in federal historic preservation reviews generated by these unprecedented circumstances by posting a suite of frequently asked questions, links, and other advice on its website. Due to the ongoing nature of pandemic emergency response efforts, the ACHP extended the time within which the special emergency review procedures in the Section 106 regulations can be used for undertakings responding to COVID-19, set to expire on March 31, 2021. Another finding identified an avenue for improving the efficiency and cost effectiveness of project review for infrastructure projects affecting historic properties on federal lands through strengthening and expanding the use of Section 106 program alternatives. Over the last three years, the ACHP has worked with numerous agencies in evaluating, developing, and implementing programmatic approaches to property management and infrastructure project review, including Department of the Army Program Comment for Inter-war Era Housing (2020), Department of Veterans Affairs Program Comment for Vacant and Underutilized Properties (2018), Program Comment to Exempt Consideration of Effects to Rail Properties within Rail Rights-of-Way (2018), and the USDA-Rural Development Nationwide Programmatic Agreement for Sequencing Section 106 (2018). Other actions designed to enhance the efficiency of infrastructure project reviews while ensuring consideration of historic properties included the ACHP’s participation as a member of the Federal Permitting Improvement Steering Council, the Broadband Interagency Working Group, and as a signatory to the 2018 Memorandum of Understanding Implementing One Federal Decision Under Executive Order 13807. The ACHP assists other federal permitting and land-managing agencies in coordinating their NHPA responsibilities with other environmental laws and regulations when collaborating in these initiatives. Participation in interagency coordination efforts has helped contribute to the improvement of permitting processes and promoted consideration of historic properties at both the project and policy levels. The ACHP also took steps to help agencies identify opportunities to improve coordination, collaboration, and support for State and Tribal Historic Preservation Officers and Indian tribes in Section 106 reviews on infrastructure projects, such as through new Guidance on Assistance to Consulting Parties in the Section 106 Review Process (2018) and Early Coordination with Indian Tribes in Pre-Application Processes: A Handbook (2019). The ACHP encouraged early coordination with Indian tribes by distributing the new Handbook to federal agencies and the Federal Permitting Improvement Steering Council and by speaking at conferences to tribal, federal, and industry audiences. In 2018, federal agencies’ reports noted their efforts to comply with “Reduce the Footprint” requirements and identified challenges in balancing the need to dispose of or find alternative uses for federal property with preservation approaches. The report urged further development of policies and procedures to assist them in considering historic properties in fulfilling these requirements and noted how reuse of historic facilities by federal agencies or others creates cost-effective preservation outcomes. In October 2019, then-Chairman Aimee Jorjani formed a Leveraging Federal Historic Buildings Working Group to help the ACHP develop recommendations for overcoming obstacles to increased leasing of federal historic buildings to nonfederal partners, and to provide guidance on


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