The Advisory Council on Historic Preservation (ACHP) is currently seeking feedback and questions on their Program Comment on Accessible, Climate Resilient, Connected Communities. The proposed Program Comment aims to accelerate historic preservation reviews by providing an alternative path for federal agencies to comply with Section 106 of the National Historic Preservation Act (NHPA) on a broad range of federal projects including housing, energy efficiency and greenhouse gas emissions in buildings, and climate friendly transportation projects. 

The Program Comment, as proposed, would apply to all agencies proposing to carry out, permit, license, fund, assist, or approve covered federal undertakings nationwide. This Program Comment would have a far larger reach and apply more broadly than any program-specific or agency-specific program alternatives previously developed. While Preservation Action appreciates the housing and energy efficiency goals expressed in the PC, and fully shares the desire for historic preservation to be an active partner in solving these pressing issues, we have serious concerns about the Program Comment, as proposed, and the process by which it was introduced. Here are some of our major concerns:

- The process did not allow for adequate consultation with impacted parties considering the broad scope of the proposal and potential to set precedent for future ACHP actions
- The Program Comment, as proposed, fails to identify, using supporting data, how the projects and undertakings covered by the Program Comment are being delayed by the current Section 106 process. 
- The Program Comment, as proposed, eliminates consultation with State and Tribal Historic Preservation Officers (SHPOs/THPOs) and the public at large, part of the fundamental intent of the NHPA, on virtually any federal undertaking related to housing or energy efficiency. 
- The Program Comment, as proposed, conflicts with numerous local preservation ordinances and state programmatic agreements, adding more complexity and confusion to the process, therefore causing further project delays.

Preservation Action is currently preparing written feedback to the Program Comment and working with our national preservation partners in responding to the proposal. Our partners at the National Conference of State Historic Preservation Officers (NCSHPO) have laid out several issues with the Program Comment and are currently collecting responses from various organizations to feature as a resource for other preservation professionals. You can also submit your own comments to include on the list by emailing info@ncshpo.org. 

We encourage everyone to participate in the process and provide feedback. Feedback to the ACHP is due by Oct. 9th. Review the proposal and submit your written comments today!