The U.S Army is developing a nationwide agreement for the treatment of all historic housing constructed between the two world wars. The “program comment” is an option for an overarching agreement between the Army and the Advisory Council on Historic Preservation (ACHP) to address all “maintenance, repair, rehabilitation, renovation, abatement, mothballing, demolition, replacement transfer, sale and lease” of family housing constructed between 1919-1940.
Army has identified some 2700 total historic housing units on 35 installations across the country. Hawai‘i has the second-highest number of units with 386, following only Ft. Benning, GA with 492.
Historic housing areas include Wheeler Army Airfield’s housing district that follows the Garden City design plan with Mission-style houses and the craftsman-style houses in the Canby neighborhood at Schofield Barracks. The program comment will not apply to National Historic Landmarks, such as the Palm Circle NHL at Fort Shafter.
Army stated that the national agreement is needed as it addresses lead paint and other hazardous materials. The agency also prioritizes addressing inefficiencies that occur from reviewing each project for housing units separately with inconsistencies between installations.
To develop the agreement, Army initiated consultation with stakeholders in October 2019 and continues with monthly conference calls on specific issues. Consulting parties include the ACHP, State and Tribal Historic Preservation Officers, the National Trust for Historic Preservation, the National Conference of State Historic Preservation Officers and Historic Hawai‘i Foundation.
A key provision of the agreement will address design guidelines for rehabilitation and treatment of the historic buildings, especially as Army replaces elements that are contaminated with lead paint. The first draft guidelines garnered 254 individual comments, with HHF submitting some 60 comments (24% of the total) on how the guidelines would apply to Hawaii’s historic properties.
HHF is primarily concerned that the draft guidelines do not recognize regional distinctions and do not protect the character-defining features of a particular installation. Hawaii’s craftsman bungalows represent a unique adaptation to the climate and the grouping at Schofield Barracks is stated to be the only remaining neighborhood of this housing type in the Army inventory. HHF also expressed concern about technical details related to proposed replacement materials, as well as the scope for proposed tracking, reporting and educational provisions.
The consultation process concluded in July and the Army submitted its proposal to the Advisory Council on Historic Preservation (ACHP), which is now accepting public comments before taking final action. The program comments only address architectural resources and not cultural or archaeological properties. However, the local programmatic agreements with U.S. Army Garrison Hawai‘i on its privatized housing program address all historic properties—both buildings and sites—so it remains to be determined how the nationwide agreement would replace, supplement or integrate with existing agreements.
PUBLIC COMMENT
The text of the proposed Program Comment and two appendices, along with information on how to provide comments, can be accessed through ACHP’s Army Program Comment Website at https://www.achp.gov/army/public-review-inter-war-housing-program-comment. Deadline: Monday, August 17, 2020.
Formal notice from The Advisory Council on Historic Preservation (ACHP):
The Advisory Council on Historic Preservation (ACHPhas received a formal request from the Department of Army (Army) to issue a Program Comment to address management actions related to its inventory of Inter-War Era (1919-1940) Historic Housing, Associated Buildings and Structures, and Landscape Features.
A Program Comment is an alternative process available to federal agencies to assist them in complying with the requirements of Section 106 of the National Historic Preservation Act (NHPA). Section 106 requires federal agencies to take into account the effects of projects they carry out, license, or assist (undertakings) on historic properties and provide the ACHP a reasonable opportunity to comment on such undertakings. The ACHP is the federal agency tasked with overseeing the Section 106 review process and issuing its implementing regulations at 36 CFR part 800. Under Section 800.14(e), federal agencies may request that the ACHP comment on a particular program or category of undertakings, so that they may proceed in accordance with those comments in lieu of conducting individual reviews of each undertaking as set forth in 36 CFR parts 800.3. through 800.7. A federal agency can meet its Section 106 responsibilities for a category of undertakings by taking into account the ACHP’s Program Comment and by following the steps set forth in those comments.
The intent of this Program Comment is to establish procedures for the Army’s management of its nation-wide inventory of over 3,200 Inter-War Era housing units that balance historic preservation requirements with its responsibility to provide the thousands of military families who live in this historic housing with the quality of life, health, and safety they require. The Program Comment would enable the Army to carry out a category of frequent and recurring undertakings relating to Inter-War Era housing identified as management actions, including maintenance, repair, rehabilitation, renovation, abatement, mothballing, demolition, replacement, transfer, sale, and lease. Because these actions present a potential for adverse effects to historic properties, the Army has identified treatment measures to mitigate the adverse effects of these undertakings. The treatment measures include the development of two documents appended to the Program Comment, Design Guidelines (Appendix A) and a Building Materials Catalog (Appendix B). This proposed Program Comment reflects input the ACHP provided to the Army and incorporates feedback provided to the Army during its own public and consulting party participation period, which occurred from November 2019 to June 2020.
Upon receiving a formal request for a Program Comment, the ACHP is responsible for consultation with State Historic Preservation Officers (SHPOs), Indian tribes, and Native Hawaiian Organizations (NHOs). Through this notification, the ACHP is seeking the views of the general public on the proposed Program Comment. The text of the proposed Program Comment and two appendices, along with information on how to provide comments, can be accessed through ACHP’s Army Program Comment Website at https://www.achp.gov/army/public-review-inter-war-housing-program-comment.
Those interested in commenting on the proposed Program Comment may do so by emailing their comments so they are received by the ACHP on or before Monday, August 17, 2020. The ACHP will consider these comments as it works to respond to Army’s request in accordance with the provisions of 800.14(e).
Should you have any questions or require additional assistance, please contact the ACHP’s Army Liaison, Rachael Mangum at (202) 517-0214 or by e-mail at rmangum@achp.gov.