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Draft Program Comment for Department of Defense Rehabilitation Treatment Measures

Section 106 of the National Historic Preservation Act requires federal agencies to consider the effects of their undertakings on historic properties and provide the Advisory Council on Historic Preservation (ACHP) a reasonable opportunity to comment with regard to such undertakings. The ACHP has issued the regulations that set forth the process through which federal agencies comply with these duties. Those regulations are codified under 36 CFR part 800 (Section 106 regulations).

Under Section 800.14(e) of those regulations, agencies can request the ACHP to provide a “Program Comment” on a particular category of undertakings in lieu of conducting individual reviews of each individual undertaking under such category, as set forth in 36 CFR 800.4 through 800.7. An agency can meet its Section 106 responsibilities with regard to the effects of particular aspects of those undertakings by taking into account ACHP’s Program Comment and by following the steps set forth in that comment.

The ACHP is now considering issuing a Program Comment to the Department of Defense (DoD), covering rehabilitation treatment measures for: (1) the removal of mortar joints and repointing; (2) preparation of lime and cement-amended mortars; (3) preparation of lime- or Portland-based stucco; (4) identifying masonry types and failures; and (5) repair and replacement of historic stucco. The Program Comment would include a process for adding new rehabilitation treatment measures, updating existing ones, and removing those that may not be working as intended.

The comment period is now open and will close on October 20, 2008.

Comments should be directed to the Advisory Council on Historic Preservation c/o Héctor Abreu Cintrón either by e-mail at or by mail 1100 Pennsylvania Avenue NW, Suite 803, Washington, DC 20004 or by fax at 202-606-5072.

Read the draft Program Comment and Appendices here.

Read the Federal Register announcement here.

The ACHP has developed guidance on the issuance of program comments as a program alternative for meeting the requirements of Section 106.  These guidelines are available at

For more information contact Héctor Abreu Cintrón at (202) 606-8517.

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