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Request for Public Comment Re: Section 106 Compliance

The Advisory Council on Historic Preservation (ACHP) is now considering issuing a program comment to the U.S. General Services Administration (GSA) which would streamline Section 106 compliance for select repairs and upgrades to windows, lighting, roofing, and heating, ventilating, and air-conditioning (HVAC) systems.  See the list of potential limited scope GSA projects subject to the American Recovery and Reinvestment Act (ARRA).  The GSA program comment is an innovative, proactive approach that GSA is taking to comply with Section 106 requirements of the National Historic Preservation Act for ARRA stimulated projects in our historic buildings nationwide.  We were simply trying to give the public another shot at accessing this information, which is a win/win for GSA historic preservation and ARRA.

While the proposed program comment may be applied to the types of projects noted above at all of GSA’s historic public buildings, the repairs and upgrades must be undertaken using GSA’s Technical Preservation Guidelines (Guidelines), written by the GSA’s Center for Historic Buildings, Office of the Chief Architect, Public Buildings Service. These Guidelines are available at GSA Technical Preservation Guidelines website. 

In addition, the repairs and upgrades contemplated by the proposed program comment would be limited to projects executed by GSA employees and contractors who meet the professional standards developed by the Secretary of the Interior. The program comment would be further limited to those projects where the proposed repairs and upgrades would not adversely affect the qualities that qualify a subject building for the National Register of Historic Places.

Just as the ARRA legislation has provided GSA with significant stewardship opportunities for its historic public buildings, the rigid spending deadline associated with the legislation has prompted the need for this alternative approach to preservation compliance for the mentioned select routine repairs and upgrades. The resulting proposed program comment, which may be applied to ARRA-funded projects and projects with other funding sources, was conceived to promote best preservation practices.  The proposed program comment could satisfy preservation compliance requirements, facilitate GSA’s efforts to meet its upcoming ARRA spending deadlines, and reduce the ARRA-related workload for GSA, ACHP, State Historic Preservation Officers, and consulting parties. Once the public comments resulting from this notice are considered, and edits are incorporated as deemed appropriate, the ACHP will decide whether to issue the program comment. The ACHP expects to make that decision at its upcoming quarterly meeting scheduled on August 7, 2009 in Washington, DC or shortly thereafter. The ACHP seeks public input on the proposed program comment and more information is available online at ACHP website.

Comments on this ACHP program comment should be directed to Kirsten Kulis, ACHP/GSA Liaison at kkulis@achp.gov by July 20, 2009.