Recommendations of ACHP Program Comment Review Panel

10/05/2021 3:42 PM | ACRAsphere Blog Team

From the ACHP:

A panel of ACHP members, charged with considering the successes and challenges key stakeholders have had in developing and using Program Comments and identifying actions the ACHP can take to improve their use as a tool for Section 106 review efficiency, recently delivered recommendations to the ACHP Vice Chairman, who is carrying out the duties of the Chairman during that position’s current vacancy. They can be accessed at: The Vice Chairman has directed staff to begin implementing these recommendations.

Program Comments (36 CFR § 800.14(e)), one of five program alternatives available in the Section 106 regulations, allow the ACHP to issue comments on a program or class of undertakings in lieu of an agency conducting reviews on a case-by-case basis. The ACHP membership must vote to approve or decline to comment after a 45-day period following an agency’s submission of a formal request for a Program Comment.

The recommendations outline a series of actions the ACHP will take to develop enhanced guidance and best practices for the development of Program Comment requests and to facilitate communication between requesting federal agencies and the ACHP on questions and concerns so they may be addressed to the extent possible before an agency makes a formal request to the ACHP, starting the 45-day review period. The recommendations do not alter any of the requirements in the regulations but do encourage planning approaches that can assist the federal agency in development of successful Program Comment proposals.

As updated guidance and best practices are developed per the recommendations, information will be posted on the ACHP’s Program Comment webpage.

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