About This Webinar: 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 to learn more about the Program Comments and ask questions. Click here to register for the webinar.
The goal of the current ACHP Program Comment is to accelerate historic preservation review timelines for federal projects related to housing, climate-smart buildings, and climate-friendly transportation. They include:
Allowing certain sitework and façade projects to proceed with limited or no review, simplifying routine maintenance and care of existing buildings as well as speeding climate resiliency upgrades.
Allowing the installation of certain solar panels on historic buildings involved in federal government projects without further historic preservation review.
Facilitating the electrification of historic buildings by exempting or streamlining reviews for mechanical and electrical system upgrades, including retrofits and installations of new all-electric energy-efficient appliances and building systems, including heat pumps.
Broadening the scope of building envelope energy efficiency improvements, including replacement windows, doors, and insulation, without further historic preservation review.
Facilitating pedestrian, bicycle, micromobility, and public transit projects.
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 9. Additional information can be found here.