4310-K6
ADVISORY COUNCIL ON HISTORIC PRESERVATION
Notice of issuance of the Department of the Army Program Comment
for the Preservation of Pre-1919 Historic Army Housing,
Associated Buildings and Structures, and Landscape Features
AGENCY: Advisory Council on Historic Preservation.
ACTION: Notice of issuance of the Department of the Army Program
Comment for the Preservation of Pre-1919 Historic Army Housing,
Associated Buildings and Structures, and Landscape Features
SUMMARY: The Advisory Council on Historic Preservation has
issued a program comment for the U.S. Department of the Army
that sets forth the way in which the Army complies with section
106 of the National Historic Preservation Act for its inventory
of housing constructed prior to 1919. Management actions covered
by the Program Comment include maintenance, repair,
rehabilitation, abatement of hazardous materials, mothballing,
lease, transfer, and conveyance.
DATES: The Program Comment went into effect on May 17, 2024.
ADDRESSES: Address any questions concerning the Program Comment
to Lauren Cooper, Office of Federal Agency Programs, Advisory
Council on Historic Preservation, 401 F Street NW, Suite 308,
Washington DC 20001.
FOR FURTHER INFORMATION CONTACT: Lauren Cooper, ACHP Army
Liaison, (202) 517-0213, lcooper@achp.gov.
SUPPLEMENTARY INFORMTATION: Section 106 of the National Historic
Preservation Act, 54 USC 306108 (section 106), requires federal

agencies to consider the effects of projects they carry out,
license, or assist (undertakings) on historic properties and to
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 on a case-by-case basis, 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 those
undertakings by taking into account an applicable program
comment and following the steps set forth in that comment.

The

U.S. Department of the Army (Army) sought a program comment for
undertakings related to its inventory of approximately 865
housing units constructed prior to 1919, many of which are
National Historic Landmarks.

Management actions covered by the

Program Comment include maintenance, repair, rehabilitation,
abatement of hazardous materials, mothballing, lease, transfer,
and conveyance, and the Program Comment allows the use of modern
readily available industry standard building materials and
methods in the implementation of management actions.

The ACHP issued the Program Comment for the Preservation of Pre1919 Historic Army Housing, Associated Buildings and Structures,
and Landscape Features on May 17, 2024. The section 106
regulations require that such program comments be published in
the Federal Register.
I. Need for the Program Comment
The need for this Program Comment is based on the Army’s
obligation to provide safe, healthy, quality housing to Soldiers
and their families, and the unique challenges the Army has in
managing NHPA section 106 compliance for its large and growing
inventory of historic housing. Housing and associated living
conditions are critical factors for military families. A direct
connection exists between poor housing conditions and military
readiness. In 2019, the Secretary of the Army declared an Army
Housing Crisis due primarily to widespread deficiencies and
significant quality of life, health, and safety issues affecting
military families living in historic Army housing.
To address the Army Housing Crisis and meet its housing
obligations to military families, the Army must quickly and
efficiently implement management actions to improve conditions
in housing constructed before 1919.

The section 106 project-by-

project review process under existing installation-level
Programmatic Agreements (PAs) contributes to delays in
completing historic housing maintenance, repairs, and
improvements needed for the transition in occupancy. Those

delays directly impact the ability of reassigned military
families to move into and occupy historic housing.
The compliance process efficiencies created by the Program
Comment allows the Army to quickly and efficiently address the
health and safety risks from certain hazardous historic building
materials, ensure cost efficient, effective, and consistent
management of the overall inventory, and implement climate
adaptations and use modern resilient materials.
II. Pre-1919 Housing and the Program Comment
The Army owns, operates, and manages the largest inventory
of historic housing in the federal government with over 30,000
historic homes currently over 50 years old and subject to NHPA
section 106 compliance. Approximately 867 of these historic
units were constructed prior to 1919, and over 70% of these pre1919 units have been designated as National Historic Landmarks.
The Army’s inventory of pre-1919 housing is located at 19
installations in 13 states and the District of Columbia.
The design and construction of the vast majority of Army pre1919 housing follows standardized plans developed by the Army
Quartermaster Corps. These standardized plans reflected
prevailing civilian architectural designs, construction
techniques, and community planning trends of the time, with
certain regional style variations and use of locally available
materials.

The resulting architectural styles of pre-1919 Army

homes include Federal, Gothic Revival, Greek Revival,
Italianate, Romanesque, Queen Anne, Colonial Revival, Spanish

Revival, and Craftsman. These houses have been continuously
occupied by Army families for 100 to 200 years and are actively
used military assets.
The intent of the Program Comment is to provide the Army
with NHPA section 106 compliance for repetitive, recurring
property management actions on all privatized and non-privatized
Army housing, associated buildings and structures, and landscape
features constructed before 1919. The property management
actions addressed by the Program Comment are maintenance,
repair, rehabilitation, abatement of hazardous materials,
mothballing, lease, transfer, and conveyance.

The Program

Comment also allows for the use of modern, industry-standard
substitute materials. If the management actions are implemented
in accordance with the Secretary of the Interior Standards for
Rehabilitation, they will not result in an adverse effect.
This Program Comment implements the Secretary’s Standards for
Rehabilitation through the methodology and procedures in
sections 7 and 8.

These procedures consider the need to

maintain the historic and architectural character of pre-1919
housing in a balanced priority with cost, climate resiliency,
materials durability, and the health, safety, and quality of
life considerations for military families living in pre-1919
housing. To further ensure that proper planning for and use of
appropriate building materials occurs, this Program Comment
includes two preservation planning documents: Design Guidelines
for Pre- 1919 Army Housing and Building Materials Guidelines and

Catalog for Pre-1919 Army Housing incorporated as Appendices A
and B, respectively.
III. Consultation on the Program Comment
The Army formally submitted this Program Comment to the
ACHP on March 4, 2024.

During the Army’s consultation period,

they sought participation from the public, State Historic
Preservation Officers (SHPOs), Indian tribes, Native Hawaiian
Organizations (NHOs), and other interested parties.

The Army

incorporated these into the Program Comment prior to formally
submitting its request for a Program Comment to the ACHP.
In accordance with 36 CFR 800.14(e)(2)(3)(4), the ACHP conducted
consultation with State Historic Preservation Officers (SHPOs),
Tribal Historic Preservation Officers, Indian Tribes, and Native
Hawaiian organizations and provided for public participation.
ACHP outreach consisted of broadcast emails, social media
posts, and a dedicated website for the Program Comment. The ACHP
conducted one virtual government-to-government consultation with
Indian Tribes with a total of two participants. The ACHP
conducted one virtual SHPO meeting with a total of 18
participants. Eight written comments were received. The ACHP
also hosted a special Membership meeting.

During consultation,

the ACHP received substantive comments regarding the use of
qualified historic preservation professionals in the
implementation of the Program Comment, the definition of lease,
transfer, and conveyance, the annual reporting requirements, new
construction, and the inclusion of National Historic Landmarks.

Several consulting parties questioned how and when Secretary of
the Interior (SOI) qualified professionals will be used in the
implementation of the PC. ACHP staff revised the PC to use
consistent language when referencing qualified historic
preservation professionals, and to more clearly define their
role when implementing the PC.
The definition of lease, transfer and conveyance was
perceived as too broad and raised questions about how it could
be misunderstood. ACHP staff worked with the Army to revise the
definition of lease, transfer, and conveyance to clarify which
specific actions are covered by the PC.
Consulting parties had concerns regarding the PC’s duration
and limited reporting requirements. ACHP staff and the Army
revised the PC to require summary data in each ACHP Section 3
report until 2055, which is published every three years and is
accessible by the public. The summary data will include items
similar to the annual report, including any issues that arose
when implementing the Program Comment, and how those problems
were addressed, and an assessment of the overall effectiveness
of the Program Comment.
The Guidelines for new construction as originally written
were broad and could potentially have resulted in adverse
effects. ACHP staff added parameters to limit new construction
to landscape features and associated buildings such as garages
and sheds, rather than new housing where none currently exists.

Consulting parties had concerns about the inclusion of National
Historic Landmarks (NHL) in the PC and feel that it does not
provide the higher standard of care as required in section 110
of the National Historic Preservation Act. However, if the
management actions are completed following the procedures and
guidelines in the PC, the results will not be adverse and will
maintain the integrity of all properties, including NHLs. The
ACHP has no reason to believe that the rehabilitation activities
allowed under this PC will not be completed following the SOI
Standards. Accordingly, use of the PC does not conflict with
section 110(f).
ACHP Staff worked with the Army to address these comments
and concerns. And all changes are reflected in the final text of
the Program Comment.
IV. More Information
For further information on the Program Comment and the
Army’s Pre-1919 historic housing see:
https://www.denix.osd.mil/army-pre1919-pchh/.
V. Clarification regarding Army Housing Partners
The ACHP interprets the Program Comment to allow the Army
to ensure compliance with its terms regarding privatized housing
by imposing such requirements on its housing partners.
VI. Text of the Program Comment
Due to their length, the appendices of the issued Program
Comment are not reproduced here. A copy of the full Program
Comment with its appendices, and related information, can be

found at: https://www.denix.osd.mil/army-pre1919-pchh/. The
Program Comment with appendices is the document linked as
“Program Comment Pre-1919 Army Housing” under the Administrative
and Technical Documents column of the web page.
What follows is the text of the issued Program Comment,
minus its appendices:
PROGRAM COMMENT FOR PRESERVATION OF PRE-1919 HISTORIC ARMY
HOUSING, ASSOCIATED BUILDINGS AND STRUCTURES, AND LANDSCAPE
FEATURES
1.0. INTRODUCTION
1.1. Summary
The Department of the Army (Army) is a large, complex
Federal agency with a national defense mission to provide
combat-ready military forces to deter war and protect the
security of the United States. The Army’s real property is a
vital component of its national defense mission. As the largest
military department in the Department of Defense (DoD), the Army
manages the largest portfolio of historic buildings in the DoD
and among all federal agencies.
Many of the buildings constructed by the Army over its 248year history are now historic properties. Among Army historic
properties, historic housing is a significant concern; it is a
large part of the Army’s total housing inventory, it is critical
to the readiness mission and well-being of thousands of Soldiers
and their families, and it requires substantial financial
resources and process time for compliance with section 106 of

the National Historic Preservation Act (NHPA). The Army also has
a unique and significant challenge among federal agencies in
managing NHPA section 106 compliance for its inventory of
historic housing. The Army owns, operates, and manages the
largest inventory of historic housing in the federal government
with over 30,000 historic homes currently over 50 years old and
subject to NHPA section 106 compliance.1
The Army’s 867 pre-1919 homes are located on 19
installations in 13 states and the District of Columbia.2 The
Army constructed its pre-1919 housing following standardized
plans developed by the Army Quartermaster Corps. The Army’s pre1919 homes have been continuously occupied by Army families for
100 to 200 years, and 74% (638) of these homes are contributing
properties in designated National Historic Landmark (NHL)
districts. The Army’s pre-1919 homes are actively used military
assets with restricted access and are in general not open to the
public.
The management of the vast majority of pre-1919 Army homes
was privatized at Army installations beginning in 2004. NHPA
compliance activities on installations with privatized housing
have occurred following NHPA section 106 programmatic agreements
(PA) executed between each installation and their respective
State Historic Preservation Office (SHPO) at the time of

Additional information on historic Army housing in general is on the
Army Historic Preservation and Cultural Resources Management website
at https://www.denix.osd.mil/army-cr/.
2 Specific information on pre-1919 Army housing is at
https://www.denix.osd.mil/army-pre1919-pchh/.

privatization. The installation specific privatized housing PAs
require project-by-project SHPO review and application of the
Secretary of the Interior's Standards for the Treatment of
Historic Properties at 36 CFR 68 (Secretary’s Standards) for the
repair and improvement of historic housing.
In 2019, the Army Inspector General3 conducted an Army-wide
review of privatized housing operations including a review of
NHPA compliance for historic homes under the installation-level
privatized housing PAs and the Secretary’s Standards. The Army
Inspector General found that the NHPA consultation process with
SHPOs under the privatized housing PAs is highly procedural and
time-consuming, creates a misperception that the SHPO has
approval authority over renovations, historic homes are more
costly to operate and maintain, are less energy efficient and
require special materials and specially trained craftsmen, and
health and safety concerns are present such as lead-based paint
and asbestos. The Army Inspector General also found that
historic homes are very costly to renovate due to strict rules
about the craftsmanship and types of materials that can be used
such as custom windows and custom roofing. These complicate
repair and renovation projects and increase costs and the time
to complete the work. The Army Inspector General also found that
the rules and restrictions are variable both by individual home
and by installation.

Department of the Army Inspector General Special Interest Item
Assessment of the Residential Communities Initiative (RCI). ID Report
1903, 2019, at https://www.denix.osd.mil/army-pre1919-pchh/.

The installation-level privatized housing PAs and the
Secretary’s Standards as implemented by SHPOs and installations
over the past 20 years have required the extensive use of highcost historic building materials, in-kind building materials and
specialized craftsmen for repairs and improvements.
Implementation of those PAs has occurred without adequate
consideration of the impact those high-cost materials have on
the long-term ability to maintain and improve historic Army
housing, nor has there been adequate consideration of the use of
lower cost substitute building materials. The installation-level
privatized housing PAs as they have been implemented has led to
the inability to fully implement scopes of work to maintain,
repair, and improve pre-1919 housing.4 The inability to fully
implement scopes of work has contributed to a costly backlog of
deferred maintenance, repairs, and improvements, which has led
some pre-1919 NHL homes to be entirely vacated, others to be
considered for demolition,5 and other pre-1919 homes to be
mandated by Congress for demolition.6 Quality of life, health,
and safety issues remain prevalent in pre-1919 Army housing.
These issues include obsolete electrical, plumbing, and HVAC
systems, structural issues, asbestos and lead-based paint
hazards, restrictive and outdated floorplans, and a backlog of
deferred maintenance, repairs, and improvements.

See Supplemental Information Briefing at
https://www.denix.osd.mil/army-pre1919-pchh/.
5 The Kansas City Star. “89 historic Fort Leavenworth homes recommended
for demolition” Eric Alder, 20 December 2023.
6 National Defense Authorization Act 2023, section 2104, Demolition of
District of Columbia Fort McNair Quarters 4, 13, and 15.

The Army Inspector General recommended that the Assistant
Secretary of the Army for Installations, Energy and Environment
(ASA IE&E) evaluate the feasibility of continuing the
installation specific PAs for historic housing. That evaluation
led to consideration of the programmatic alternatives available
in 36 CFR 800.14. The Army determined that a standardized
nation-wide programmatic approach was the best course of action
to ensure more consistent, efficient, and effective approach to
NHPA compliance, rather than to continue to operate under the
installation specific PAs. This approach was defined in the ASA
IE&E’s Strategic Agenda for National Historic Preservation Act
Improvement7 issued in July 2019.
Installation-level privatized housing PAs and the
Secretary’s Standards have been implemented by installations and
SHPOs over the past 20 years without a systematic approach and
methodology for the selection of building materials. Also,
adequate attention has not been paid by installations and SHPOs
to the requirement that the Secretary’s Standards must be
applied in consideration of the economic and technical
feasibility of each project.8 Further, the installation-level
privatized housing PAs do not have any standardize process and
procedures for consideration of the full range of available and
appropriate building materials including alternative and less

Strategic Agenda for National Historic Preservation Act Improvement
letter provided to the Advisory Council on Historic Preservation is
posted at https://www.denix.osd.mil/army-pre1919-pchh/.
8 Secretary of the Interior's Standards for Treatment of Historic
Properties, 36 CFR 68.3.

costly substitute building materials as provided for under the
Secretary’s Standards for Rehabilitation (36 CFR 68.3(b)). Nor
do the privatized housing PAs include detailed design guidelines
and a catalog of applicable building materials for pre-1919
homes. Additionally, the lengthy project-by-project
consultations between installations and SHPOs required by
installation-level PAs cause delays in occupancy of the housing,
resulting in negative impacts to military families. This Program
Comment for Preservation of Pre-1919 Historic Army Housing,
Associated Buildings and Structures, and Landscape Features
(Program Comment) directly addresses and remedies these issues.
This Program Comment is the Army’s nationwide programmatic
NHPA compliance solution to longstanding pre-1919 housing
issues. It is responsive to the Army Inspector General’s
findings and recommendation, ensures that the economic and
technical feasibility of each project is assessed as required by
the Secretary’s Standards, makes certain that the full range of
building materials are considered through a systematic approach
and standardized methodology that will help reduce the backlog
of deferred maintenance, repairs, and improvements. Detailed
design guidelines, and an extensive building materials guideline
and catalog are incorporated into this Program Comment to
support the building materials selection process. Qualified
historic preservation professionals guide implementation, and
the approach will improve process time and address the delays in
occupancy of the housing by military families.

This Program Comment in its entirety minimizes harm and
manages pre-1919 NHL housing to a higher standard of care than
has occurred under installation level PAs over the past 20
years. This Program Comment is consistent with and implements
the Secretary’s Standards for Rehabilitation, and its effect on
the Army’s inventory of pre-1919 housing is not adverse. This
Program Comment demonstrates that the Secretary’s Standards for
Rehabilitation when applied as intended have the flexibility to
address quality of life, health, safety, climate resiliency,
energy efficiency and other issues in a cost-effective manner.
This Program Comment also reflects a shift occurring among
historic preservation professionals to a more humanistic
approach to historic preservation that prioritizes the needs of
people living in and managing historic homes equally with
preservation of the material integrity of the homes.9
1.2. Justification
NHPA section 106 requires Federal agencies to take into
account the effects of projects they carry out, license, or
assist (i.e., undertakings) on historic properties, and to
provide the Advisory Council on Historic Preservation (ACHP) a
reasonable opportunity to comment on such undertakings. The ACHP
has issued regulations codified under 36 CFR 800 that set forth
the process through which Federal agencies comply with the
requirements of NHPA section 106.

The Relevancy Guidebook: How We Can Transform the Future of
Preservation. Bonnie McDonald. Landmarks Illinois, November 2023.

Under 36 CFR 800.14(e), federal agencies can request the
ACHP provide program comments on a category of undertakings, in
lieu of conducting individual reviews of those undertakings
under 36 CFR 800.4 - 800.7. An agency can meet its NHPA section
106 responsibilities regarding the effects of a category of
undertakings on historic properties by following an ACHPapproved program comment.
ACHP’s program comment guidance10 states the primary benefit
of program comments is they allow a federal agency to comply
with section 106 of the NHPA in a tailored, consistent way for a
class of undertakings rather than addressing each undertaking
individually. This is especially useful for the Army considering
the magnitude of its historic housing inventory and the many
thousands of similar repetitive undertakings occurring to
repair, maintain, and improve this large housing inventory. This
Program Comment provides the Army with an alternative means to
comply with NHPA section 106 regarding the category of
undertakings termed management actions for its inventory of pre1919 housing, associated buildings and structures, and landscape
features (pre-1919 housing).
The need for this Program Comment is driven by the Army’s
obligation to provide safe, healthy, quality housing to Soldiers
and their families, and the unique challenges the Army has in
managing NHPA section 106 compliance for its large inventory of
historic housing. In 2019, the Secretary of the Army declared an
ACHP Program Comment Guidance https://www.achp.gov/program comment
questions and answers.

Army Housing Crisis due primarily to the widespread deficiencies
and significant quality of life, health, and safety issues
affecting military families living in historic Army housing.
These issues led to the Army Inspector General’s investigation
and continue to receive a high level of attention from Congress,
senior military officials, and military family members residing
in historic Army homes.
To meet its obligations to military families, the Army must
implement specific management actions to improve pre-1919
housing conditions. The Army must improve the quality of life of
Soldiers and their families, address the health and safety risks
from certain hazardous materials found in historic housing,
ensure cost efficient, effective, and consistent management of
the inventory, and use climate resilient and energy efficient
building materials. The Army must also improve the NHPA section
106 compliance processes time for projects that improve and
preserve pre-1919 housing in order to reduce impacts to military
families waiting to occupy the housing.
Housing and associated material living conditions are
critical factors for military families in the context of the
challenges and stressors Soldiers and their families must cope
with in their daily lives. The Government Accountability Office11
found that a direct connection exists between poor housing
conditions and military readiness. Concerns among service
members about poor housing conditions have been found to make it
Government Accountability Office Report 20-281, Military Housing,
March 2020.

difficult to focus on the military mission, some service members
are leaving the military because of poor housing conditions, and
the issue is also impacting the ability to recruit new service
members.
For pre-1919 housing, the Army must abate the historic
building materials used in housing from this period that present
lead-based paint, asbestos, and other hazards to housing
occupants; implement improvements and additions that address the
need for modernization of living spaces; provide kitchen and
bathroom improvements; implement climate change adaptations
through the use of climate resilient and energy efficient
building materials; implement other energy efficiency measures;
modernize heating, cooling and ventilation systems; modernize
plumbing and electrical systems; install modern life safety and
protective elements such as fire suppression systems and force
protection features; and address the project-by-project PA
compliance review process that affects the rapid turnaround and
occupancy of housing by military families.
The Army also has the need to lease, transfer, or convey
pre-1919 housing to facilitate housing operations by its
privatized housing partners under the Army’s Residential
Communities Initiative (RCI). RCI operates under Army authority
on Army installations nationwide through legal partnerships
between the Army and private sector real property managers.
Lease, transfer, and conveyance under this Program Comment is
only for the purposes of transfer of pre-1919 housing to and

between RCI partners, and between RCI partners and the Army
solely for the purposes of and use as military housing and for
associated purposes that support military housing operations.
Addressing NHPA section 106 compliance requirements for the
thousands of repetitive management actions occurring on this
large inventory of pre-1919 housing presents unique and
significant challenges for the Army. According to the ACHP
Program Comment Guidance, the program comment approach as
provided for in 36 CFR 800.14(e) was established to address
situations such as this, where a federal agency has repetitive
actions occurring within a large inventory of historic
properties.
The Army’s three prior ACHP-approved program comments for
historic housing (Program Comment for Army Inter-War era housing
(1919-1940), Program Comment for Army Capehart-Wherry Housing
(1949-1962), and the Program Comment for Army Vietnam War Era
housing (1963-1975)) provide the Army the ability to implement
management actions in a more efficient, consistent, and costeffective manner.12 These prior program comments have in turn
preserved the historic character of the housing, improved the
quality of life, health, and safety of the military families
living in historic Army housing, saved millions of dollars in
rehabilitation costs for reinvestment into additional
rehabilitation efforts, and ensure that historic Army housing

See information at https://www.denix.osd.mil/army-pchh/,
https://www.denix.osd.mil/army-vwehh-pc/, and ACHP section 106 Success
Story: Capehart Wherry Housing Challenge Spurred Innovative Solution
at https://www.achp.gov/success-stories/capehart-wherry-army-housing.

will be preserved as a viable and sustainable military real
property asset. The Army needs a similar efficient, consistent,
and cost-effective means to manage its inventory of pre-1919
homes.
1.3. Coordination and Public Involvement
Issues related to implementation of installation privatized
housing PAs were identified by the Army Inspector General, Army
housing managers, and Army privatized housing partners.13 As a
result of its investigation, the Army Inspector General
recommended that the ASA IE&E assess the feasibility of
continuing the installation specific PAs for historic housing.
The Strategic Agenda for National Historic Preservation Act
Improvement14 issued in July 2019 by the ASA IE&E responded to
the Army Inspector General’s recommendation. It directs the Army
Federal Preservation Officer (FPO) to pursue programmatic Armywide NHPA section 106 compliance solutions, with the ACHP to
achieve greater efficiencies in NHPA section 106 compliance for
historic housing.
To implement the strategic agenda for pre-1919 housing, the
Army’s leadership began discussions in June 2023 with the ACHP
Chair and other key stakeholders. On 15 June 2023, the ASA IE&E
held a forum at Fort McNair, Washington, DC with senior leaders
in historic preservation to discuss pre-1919 Army housing NHPA
compliance issues. Stakeholders present at the 15 June 2023

See Supplemental Information Briefing at
https://www.denix.osd.mil/army-pre1919-pchh/.
14 Strategic Agenda for National Historic Preservation Act Improvement.
July 26, 2019. https://www.denix.osd.mil/army-pre1919-pchh/.

forum included the Assistant Secretary of Defense for Energy,
Installations, and Environment; Assistant Secretary for Fish and
Wildlife and Parks, Department of the Interior; Chairman, ACHP;
Chairman, National Capital Planning Commission; Associate
Director, Cultural Resources, Partnerships, and Science,
National Park Service (NPS); Executive Director, ACHP; and the
Executive Director, National Conference of State Historic
Preservation Officers (NCSHPO). There was general agreement
among attendees that a nationwide programmatic NHPA section 106
compliance approach to pre-1919 Army housing was needed.
On 20 July 2023, as a follow-up to the Fort McNair meeting,
the Army FPO held a consultation meeting with the ACHP Executive
Director, NCSHPO Executive Director, and the NPS Associate
Director to obtain their views on specific programmatic NHPA
section 106 compliance approaches for pre-1919 housing. On 24
August 2023, the Army FPO again met with the representatives
from ACHP, NPS, and NCSHPO to further discuss a program
alternative for pre-1919 Army housing. Also on 24 August, the
Army FPO had a separate follow-on discussion with the ACHP
Executive Director. On 19 September 2023, the Army FPO
officially notified the ACHP Executive Director of the Army’s
decision to seek a program comment for its inventory of pre-1919
housing.
On October 23, 2023, the Army published a notice of
availability in the Federal Register15 seeking public comment on
Federal Register/Vol. 88, No.203/72743. 23 October 2023. Department
of the Army Notice of Availability Program Comment Plan for

its Program Comment Plan for Preservation of Pre-1919 Historic
Army Housing, Associated Buildings and Structures, and Landscape
Features. Also on October 23, 2023, the Army FPO sent a
notification to over 800 stakeholders including all SHPOs, all
Tribal Historic Preservation Officers, tribal leaders from all
Federally recognized tribes, Native Hawaiian Organizations, and
non-governmental historic preservation advocacy organizations
informing them of the Federal Register notice and the 30-day
public comment period on the program comment plan. The Army FPO
also invited all of the over 800 stakeholders to participate in
the Army’s ensuing program comment consultation conferences.
During November and December 2023, the Army FPO held a series of
six in-depth consultation conferences with all interested
parties addressing the scope of the Program Comment, category of
undertakings, likely effects on historic properties, steps to
take effects into account, the duration of the Program Comment,
among other relevant topics. The Army prepared an administrative
record of all comments on the program comment plan formally
submitted by interested parties and provided that administrative
record to the ACHP.
2.0. GOAL, OBJECTIVE, AND INTENT OF THE PROGRAM COMMENT
2.1. Goal
The Army’s goal for the Program Comment is to obtain
programmatic compliance with NHPA section 106 for the repetitive
management actions occurring on this large inventory of pre-1919
Preservation of Pre-1919 Historic Army Housing, Associated Buildings
and Structures, and Landscape Features.

historic housing by means of the program comment alternative
procedure under 36 CFR 800.14(e). In accordance with 36 CFR
800.14(e), the Army will implement this program comment and
management actions in lieu of conducting individual project-byproject reviews.
2.2. Objective
The objective of the Program Comment is to achieve the goal
in a manner that provides the appropriate balance between
preservation of the housing and the efficient, consistent, and
cost-effective management of the housing in order to improve of
the quality of life, health, and safety of the Army families.
The goal and objective are met by the ACHP’s adoption of the
Program Comment and the Army’s implementation of it for its
management actions.
2.3. Intent
This Program Comment recognizes that among federal
agencies, the Army faces a unique and significant NHPA section
106 compliance challenge due to the magnitude of its inventory
of historic housing.
This Program Comment recognizes that the Army’s pre-1919
homes are actively used military assets with restricted access
and are in general not open to the public.
The Army recognizes that its pre-1919 housing is eligible
for and listed in the National Register of Historic Places
(NRHP), and that many pre-1919 Army homes are contributing
properties in designated NHL districts.

This Program Comment meets the requirements of NHPA section
110(f) by planning and taking necessary action that minimize
harm to pre-1919 NHLs to the maximum extent possible and
provides a higher standard of care for NHL housing than is
currently occurring.
This Program Comment is consistent with the Secretary of
the Interior’s Standards for Rehabilitation (36 CFR 68.3(b)). It
provides for the compatible use of the properties through
repairs, alterations, and additions, while preserving those
portions or features which convey historical, cultural, and
architectural values.
This Program Comment covers a category of undertakings
termed management actions and affirms that the effect of those
management actions on pre-1919 Army housing are not adverse as
addressed in this Program Comment.
This Program Comment implements the Secretary’s Standards
for Rehabilitation through the methodology and procedures in
sections 7 and 8, and by application of the Design Guidelines
for Pre-1919 Army Housing and the Building Materials Guidelines
and Catalog for Pre-1919 Army Housing in appendices A and B.
This Program Comment recognizes that the Secretary of the
Interior’s Standards must be applied in consideration of the
economic and technical feasibility of each project per 36 CFR
68.3.
This Program Comment recognizes that the Secretary’s
Standards for Rehabilitation allow for the use of substitute

building materials when the use of historic building materials
and in-kind building materials is not reasonably possible in
consideration of the economic and technical feasibility of
projects.
This Program Comment recognizes that the appended Design
Guidelines for Pre-1919 Army Housing and Building Materials
Guidelines and Catalog for Pre-1919 Army Housing are applicable
guidelines (as referenced in 36 CFR 800.5(a)(2)(ii))
implementing the Secretary’s Standards for Rehabilitation for
pre-1919 Army housing.
This Program Comment provides a systematic, standardized
building materials selection procedure with guidelines that
ensure the balanced consideration of repair of historic building
materials or, where repair is not possible, the use of in-kind
building materials or substitute building materials in
management actions.
This Program Comment ensures that qualified historic
preservation professionals support its implementation.
This Program Comment recognizes that intensifying climate
risks and the ACHP’s Policy Statement on Climate Change and
Historic Preservation may necessitate the use of modern climate
resilient substitute building materials.
This Program Comment recognizes that substitute building
materials are reversible and may be replaced with in-kind
building materials to minimize any diminishment of historic
integrity.

This Program Comment recognizes that the compilation and
analysis of original Army Quartermaster Corps housing design
plans, extensive historic context documentation, and the
Historic American Building Survey (HABS) architectural
documentation of pre-1919 Army housing are suitable and
appropriate mitigation measures. These Program Comment
mitigation documents are located in a single centralized public
site at https://www.denix.osd.mil/army-pre1919-pchh/.
3.0. SCOPE OF THE PROGRAM COMMENT
The Program Comment applies to management actions for all
of the Army’s pre-1919 housing, associated buildings and
structures, and landscape features, both privatized and Armyowned. The best available information indicates there are 867
pre-1919 homes located on 19 installations in 13 states and the
District of Columbia. Among these, there are 10 installations
where pre-1919 housing has been designated as individual or
contributing properties to NHL Districts. The installations and
numbers of pre-1919 homes are: Fort Leavenworth, KS 269 homes;
Fort Riley, KS 109; Fort Sam Houston, TX 91; West Point, NY 84;
Fort Sill, OK 73; Fort Bliss, TX 39; Fort Huachuca, AZ 38;
Presidio of Monterey, CA 37; Fort Myer, VA 34; Fort McNair,
Washington DC 27; Carlisle Barracks, PA 18; US Army Garrison HI
/ Fort Shafter, 17; Watervliet Arsenal, NY 8; Rock Island
Arsenal, IL 6; Fort Hamilton, NY 6; Picatinny Arsenal, NJ 6;
Fort Detrick, MD 2; Arlington National Cemetery, VA and DC 2;
and Fort Moore, GA 1.

4.0. DESCRIPTION OF PROPERTY TYPE
Standardized plans developed by the Army Quartermaster
Corps were followed for the design and construction of the vast
majority of Army pre-1919 housing. Army Quartermaster Corps
standardized plans reflected prevailing civilian architectural
designs, construction techniques, and community planning trends
of the time, with certain regional style variations and use of
locally available materials. The Army has documented mitigation
measures for pre-1919 housing.
The mitigation documentation16 includes historic contexts, a
documentary history with an extensive compilation and analysis
of original Quartermaster Corps plans and drawings including
exterior and interior floorplans for pre-1919 homes, and many
HABS documents recording the architectural design and features
of pre-1919 Army housing in detail. The Army has posted these
mitigation documents on the website https://denix.osd.mil/armypre1919-pchh/. Additional information on the Army’s inventory of
NHLs is also available in the Army’s historic preservation
story-map at https://www.denix.osd.mil/army-cr/.
Historic context information is extensive and includes
social, economic, and military factors influencing pre-1919 home
design. Army Quartermaster Corps housing standardization began

National Historic Context for Department of Defense Installations,
1790-1940, Volumes I-4. DoD Legacy Resource Management Program Project
92-0075 (1995).
A Study of United States Army Family Housing Standardized Plans,
Volumes 1-5., Grashof, B. (1986).
Context Study of the United States Quartermaster General Standardized
Plans 1866-1942. Army Corps of Engineers, Seattle District (1997).

in earnest after the close of the Civil War. From 1866 on the
Army began its evolution into a modern military force as it
abandoned its small temporary frontier posts and consolidated
troops into larger regional installations. The need for new,
larger, permanent installations required a higher degree of
planning and design for buildings as well as post-wide site
plans.
When the Army began to contract this work to civilian
architects, mid-nineteenth century American architectural
designs began to influence both Army building and Army
installation designs. The Army Quartermaster Corps
standardization of house plans incorporated versions of
nationally popular architectural styles. Civilian builder's
handbooks, also known as pattern books, were used as source
books by the Quartermaster Corps housing design staff.17 The
resulting architectural styles of pre-1919 Army homes include
Federal, Gothic Revival, Greek Revival, Italianate, Romanesque,
Queen Anne, Colonial Revival, Spanish Revival, and Craftsman.
Following design trends of the time, the Army Quartermaster
Corps also developed standardized plans for landscaping,
neighborhood design, circulation patterns, and the design of
installations.
5.0. NATIONAL HISTORIC LANDMARKS
5.1 Pre-1919 Army NHL Housing and NHL Requirements

A Study of United States Army Family Housing Standardized Plans,
Volumes 1-5., Grashof, B. (1986).

Of the Army’s 867 historic pre-1919 homes, 74% (638) of
these homes at ten installations are contributing properties in
designated NHL districts. The ten installations with NHL
districts are: Fort Leavenworth, KS 269 homes; Fort Sam Houston,
TX 91; West Point, NY 84; Fort Sill, OK 73; Fort Huachuca, AZ
38; Fort Myer, VA 34; Carlisle Barracks, PA 18; US Army Garrison
HI / Fort Shafter, 17; Watervliet Arsenal, NY 8; Rock Island
Arsenal, IL 6. These ten NHL designations by the Department of
the Interior/National Park Service are consolidated and
published on the Program Comment website at
https://denix.osd.mil/army-pre1919-pchh/.
NHLs are designated by the Secretary of the Interior under
the authority of the Historic Sites Act of 1935. The Historic
Sites Act authorizes the Secretary of the Interior to identify
historic buildings, and other sites and objects that possess
exceptional value in commemorating or illustrating the history
of the United States. NHPA section 110(f) Planning and actions
to minimize harm to National Historic Landmarks states that
prior to the approval of any Federal undertaking that may
directly and adversely affect any NHL, the Federal agency will
to the maximum extent possible undertake such planning and
actions as may be necessary to minimize harm to the landmark.
The Federal agency also must afford the ACHP and the Secretary
of the Interior / National Park Service a reasonable opportunity
to comment with regard to the adverse effect undertaking.

The Secretary of the Interior’s Standards and Guidelines
for Federal Agency Historic Preservation Programs Pursuant to
the National Historic Preservation Act (63 FR 20496) provide the
National Park Service’s guidance to federal agencies for their
preservation programs and treatment of NHLs. The standard and
guidelines at 4(j) National Historic Landmarks states that
Federal agencies exercise a higher standard of care when
considering undertakings that may directly and adversely affect
NHLs. Standard 4 states when alternatives to avoid an adverse
effect on NHLs appear to require undue cost or to compromise the
undertaking’s goals and objectives, the agency must balance
those goals and objectives with the intent of section 110(f).
The regulations implementing NHPA section 106 include
specific procedural provisions for NHLs at 36 CFR 800.10. The
regulation requires federal agencies to request the ACHP
participate in any consultation regarding adverse effects to
NHLs, and to also invite the Secretary of the Interior /
National Park Service to participate in those consultations.
5.2. Standard of Care for Pre-1919 Army NHL Housing and
Districts
This Program Comment confirms that the effects of its
management actions on pre-1919 Army housing including pre-1919
NHL housing and districts are not adverse. Through its
conformance with and implementation of the Secretary of the
Interior Standards for Rehabilitation by means of the approach,
methodology, and procedures in sections 7 and 8 and guidelines

in appendices A and B, this Program Comment provides a more
effective NHPA section 106 compliance solution for NHLs than is
currently in place under installation-level PAs (as discussed in
section 1). The Program Comment supports full implementation of
scopes of work for maintenance, repairs, and improvements to NHL
housing by ensuring that the full range of appropriate and costeffective building materials are considered through a systematic
approach and standardized methodology. This in turn will reduce
the backlog of deferred maintenance, repairs, and improvements,
alleviating issues that lead to vacancy and considerations to
demolish pre-1919 NHL homes. It also demonstrates a more
efficient, cost-effective, programmatic solution for
rehabilitation of pre-1919 Army housing to help avoid additional
statutory mandates to demolish pre-1919 Army housing.
Further, the standard set of management actions in the
Army’s three prior Program Comment procedures for historic
housing approved by the ACHP include the following adverse
effect actions: cessation of maintenance, demolition, and new
construction not in accordance with the Secretary’s Standards
for Rehabilitation. The Army is excluding adverse effect actions
from this Program Comment. Such adverse effect actions will be
addressed outside of this Program Comment through the process in
36 CFR 800.4 - 800.7, and 36 CFR 800.10 for NHLs.
Due to the special considerations required by NHPA section
110 for NHLs and properties with national level significance,
the Army is holding this Program Comment for pre-1919 housing to

a higher standard of care than has occurred under installation
level PAs and under prior Program Comment procedures for
historic Army housing.
6.0. CATEGORY OF UNDERTAKING AND EFFECTS ON HISTORIC PROPERTIES
The category of undertaking for this Program Comment is
management actions. Management actions are defined for the
purposes of this Program Comment as maintenance, repair,
rehabilitation, abatement of hazardous materials, mothballing,
lease, transfer, and conveyance. This Program Comment is
consistent with and implements the Secretary’s Standards for
Rehabilitation at 36 CFR 68.3(b). When implemented following its
substantive and procedural requirements, this Program Comment
and the effects of those management actions on pre-1919 Army
housing are not adverse.
The regulation at 36 CFR 800.5 cites criteria for adverse
effect. “An adverse effect is found when an undertaking may
alter, directly or indirectly, any of the characteristics of a
historic property that qualify the property for inclusion in the
National Register in a manner that would diminish the integrity
of the property's location, design, setting, materials,
workmanship, feeling, or association.” The adverse effect
example in 36 CFR 800.5 relevant to this Program Comment is
alteration of a property that is not consistent with the
Secretary’s Standards (36 CFR 68), and applicable guidelines.
This Program Comment is consistent with and implements the
Secretary’s Standards for Rehabilitation. The Design Guidelines

for Pre-1919 Army Housing and the Building Materials Guidelines
and Catalog for Pre-1919 Army Housing appended to this Program
Comment are applicable guidelines. This Program Comment will
maintain the integrity of pre-1919 housing and historic district
location, design, setting, materials, workmanship, feeling, and
association consistent with the Secretary’s Standards.
This Program Comment implements a systematic approach and
standardized methodology with specific procedures for selection
of appropriate building materials that consider the economic and
technical feasibility of each project. It utilizes detailed
Design Guidelines for Pre-1919 Army Housing and a Building
Materials Guideline and Catalog for Pre-1919 Army Housing (in
appendices A and B) to support the materials selection process.
7.0. APPROACH AND METHODOLOGY
7.1. Implementation of the Secretary’s Standards for
Rehabilitation
In carrying out the management actions under this Program
Comment, the Army, or RCI housing partner where housing is
privatized will implement the Secretary’s Standards for
Rehabilitation (36 CFR 68.3(b)), taking into consideration the
economic and technical feasibility of each project by means of
the procedure in section 8 and with reference to the applicable
guidelines in appendices A and B. The Secretary’s Standards for
Rehabilitation state:
(1)

A property will be used as it was historically or be

given a new use that requires minimal change to its

distinctive materials, features, spaces and spatial
relationships;
(2)

The historic character will be retained and preserved.

The removal of distinctive materials or alteration of
features, spaces and spatial relationships that
characterize a property will be avoided;
(3)

Each property will be recognized as a physical record

of its time, place and use. Changes that create a false
sense of historical development, such as adding
conjectural features or elements from other historic
properties, will not be undertaken;
(4)

Changes to a property that have acquired historic

significance in their own right will be retained and
preserved;
(5)

Distinctive materials, features, finishes and

construction techniques or examples of craftsmanship that
characterize a property will be preserved;
(6)

Deteriorated historic features will be repaired rather

than replaced. Where the severity of deterioration
requires replacement of a distinctive feature, the new
feature will match the old in design, color, texture and,
where possible, materials. Replacement of missing
features will be substantiated by documentary and
physical evidence;
(7)

Chemical or physical treatments, if appropriate, will

be undertaken using the gentlest means possible.

Treatments that cause damage to historic materials will
not be used;
(8)

Archeological resources will be protected and

preserved in place. If such resources must be disturbed,
mitigation measures will be undertaken;
(9)

New additions, exterior alterations or related new

construction will not destroy historic materials,
features and spatial relationships that characterize the
property. The new work will be differentiated from the
old and will be compatible with the historic materials,
features, size, scale and proportion, and massing to
protect the integrity of the property and its
environment; and
(10) New additions and adjacent or related new construction
will be undertaken in such a manner that, if removed in
the future, the essential form and integrity of the
historic property and its environment would be
unimpaired.
As stated in National Park Service Preservation Brief 16
The Use of Substitute Materials on Historic Building Exteriors,18
the Secretary's Standards for Rehabilitation generally require
historic features be repaired rather than replaced. Standard 6
of the Secretary’s Standards for Rehabilitation states that when
replacement of a distinctive feature is necessary, the new
feature must “match the old in composition, design, color,
Preservation Brief 16 The Use of Substitute Materials on Historic
Building Exteriors, National Park Service, September 2023.

texture, and other visual properties, and, where possible,
materials.” While the use of in-kind materials to replace
historic building materials is preferred under the Standards for
Rehabilitation, those Standards also purposely recognize that
flexibility is needed when it comes to the use of substitute
building materials. Substitute building materials that match the
visual and physical properties of historic materials have been
successfully used by the Army on many rehabilitation projects
under the Program Comment for Army Inter-War Era housing in ways
that are consistent with the Standards for Rehabilitation.19
The Secretary's Standards for Rehabilitation standards (9)
and (10) allow for new additions, exterior alterations or
related new construction that are in accordance with those
specified standards. The Guidelines for Rehabilitation,
Additions, Exterior Alterations, and Adjacent or Related
Construction in Appendix A of this program comment implements
those requirements.
In order to ensure consistency with the Secretary’s
Standards for Rehabilitation, the Army, or RCI housing partner
where housing is privatized will implement the Secretary’s
Standards for Rehabilitation through the preservation planning
guidelines in appendices A and B, will take the economic and
technical feasibility of each project into consideration by
following the procedures in section 8, and will have qualified

See the Annual Reports submitted to the ACHP for the Program Comment
for Army Inter-War Era Housing (1919-1940) at
https://www.denix.osd.mil/army-pchh/.

historic preservation professionals available to support
application of the Secretary’s Standards for Rehabilitation and
the building materials selection process.
7.2. Preservation Planning Guidelines in Appendices A and B
The Army or RCI partner where housing is privatized will
plan for the selection and use of appropriate building materials
in the repair and rehabilitation of pre-1919 Army housing.
Specific building material selection procedures are established
in section 8 of this Program Comment that consider the need to
maintain the historic and architectural character of pre-1919
housing in a balanced priority with cost, climate resiliency,
materials durability, and the health, safety, and quality of
life considerations for military families living in pre-1919
housing. To further ensure that proper planning for and use of
appropriate building materials occurs, this Program Comment also
provides for support from qualified historic preservation
professionals (see section 11) and includes two preservation
planning documents: Design Guidelines for Pre-1919 Army Housing
and Building Materials Guidelines and Catalog for Pre-1919 Army
Housing incorporated as Appendices A and B, respectively.
The Design Guidelines for Pre-1919 Army Housing in Appendix
A provide specific information regarding pre-1919 housing
architectural styles and identify character-defining features
and design elements associated with the pre-1919 architectural
styles. Character-defining features include the overall shape,
style, and design of the building, decorative details, interior

spaces and features, as well as its associated buildings and
structures, and landscape features. The Design Guidelines for
Pre-1919 Army Housing include detailed guidance for
rehabilitation and features such as windows and doors,
entrances, porches, roofs, foundations and walls, interiors,
interior structural systems, historic designed landscapes and
features, historic districts, circulation systems, associated
buildings and structures, as well as guidance on mothballing of
housing, emergency repairs and disasters, and actions related to
military force protection requirements.
The Building Materials Guidelines and Catalog for Pre-1919
Army Housing in Appendix B is used in concert with the Design
Guidelines for Pre-1919 Army Housing. The Building Materials
Guidelines and Catalog provides additional specificity on
building materials and their use. The Building Materials
Guidelines and Catalog provides information to assist in
selecting the appropriate building materials that maintain the
historic and architectural character of the housing and meet
cost and technical feasibility requirement of the Secretary’s
Standards. Catalog entries are provided for major components of
pre-1919 housing design. Design considerations for each catalog
entry are derived from the design fundamentals of scale, mass,
proportion, and materials. This provides the guidance for
selection of appropriate materials and component designs that
factor location, type, size, finish and maintenance into their
selection. Focus is on appropriate design, applicable materials,

and performance characteristics with emphasis on retention of
overall housing design integrity.
The Building Materials Guidelines and Catalog includes inkind, and substitute building materials. A range of modern
substitute building materials are included for considerations
related to economic feasibility and technical feasibility such
as material durability, energy efficiency, and climate
resiliency. Cost and durability are factors relevant for example
to the selection of in-kind wood windows or windows made of
substitute materials such as vinyl. As stated in National Park
Service Preservation Brief 16, the poor quality of available
commercial supplies of lumber no longer provides the denser,
more decay-resistant wood of old-growth forests. Due to the poor
quality of available lumber used in the manufacture of in-kind
wood windows, modern vinyl windows are as or more durable than
today’s in-kind wood windows. This is made clear by the
manufacturer warranty periods provided for vinyl windows which
are as long or longer than the manufacturer warranties for inkind wood windows.20 Vinyl windows can also provide an adequate
visual replication of the historic windows, cost significantly
less than in-kind wood windows, have a shorter turn-around time
for manufacture and installation, improve energy efficiency, and
have lower long-term maintenance requirements.
As stated in National Park Service Preservation Brief 16,
when a substitute building material is used for replacement, a
See Supplemental Information Briefing at
https://www.denix.osd.mil/army-pre1919-pchh/.

loss in integrity can sometimes although not always occur. That
situation is mitigated by the fact that substitute building
materials are reversible and can be replaced with in-kind
materials at any point in time. Additionally, the support of
qualified historic preservation professionals (see section 11)
in the building materials selection process and monitoring of
management actions by the Army FPO will ensure that the historic
character of pre-1919 housing and historic districts is
maintained.
7.3. Consideration of Interior Spaces
The Army has extensive documentation and recordation of the
interiors of pre-1919 housing. The original floorplans designed
by the Army Quartermaster Corps for pre-1919 housing have been
collected, categorized, reproduced, and analyzed in A Study of
United States Army Family Housing Standardized Plans, Volumes 15, (Grashof, B., 1986), posted at
https://www.denix.osd.mil/army-pre1919-pchh/. The Army also has
77 HABS documents for pre-1919 housing posted at
https://www.denix.osd.mil/army-pre1919-pchh/ which represent a
sample of over 10% of the Army’s pre-1919 housing units. The
housing selected for HABS documentation are the most
representative examples of this category of Army housing and
records their setting, interiors, and exteriors. The extensive
historical documentation and analysis of original floorplans
combined with the HABS recordation of pre-1919 Army housing are

suitable and appropriate mitigation measures for this Program
Comment.
The Army’s pre-1919 homes have been continuously occupied
by Army families for 100 to 200 years and the original interior
floorplans have all been modified. Current floorplans include
rooms that were not features of the original Quartermaster Corps
design, new walls and partitions have been added to expand
kitchens and to create bathrooms and closets that were not
features of original construction. Additions have been made,
floors, walls, and ceilings have been cut through and modified
to add plumbing, electrical service, and heating and ventilation
ductwork, plaster walls have been replaced with drywall, paint
and plaster have been removed to create a new appearance. Some
of the homes have had complete renovations prior to enactment of
the NHPA; for example, Quarters 1 is a pre-1919 home at Fort
Myer, Virginia documented to have been “completely renovated” in
1953.21
The Secretary’s Standards for Rehabilitation state that
changes to a property that have acquired historic significance
in their own right will be retained and preserved. The
significance of the interiors of pre-1919 Army housing is that
they represent such changes in terms of the ongoing evolution of
interior spaces in response to changing technological, military,
and quality of life, health, and safety requirements, and

Quarters 1, Fort Myer. General Condition and Programmed
Improvements. June 20, 1967. Fort Myer Quarters 1, HABS documentation
package, posted at https://www.denix.osd.mil/army-pre1919-pchh/.

interior design trends. To maintain their significance, the
interiors must continue to develop and change in response to
changing military, technological, and social needs, and such
changes will acquire future historic significance in their own
right. The interiors of pre-1919 Army housing could be adversely
affected if their development were frozen at an arbitrary point
in time.
The Design Guidelines for Pre-1919 Army Housing in Appendix
A contain Guidelines for Interiors. In consideration of the
above, the Guidelines for Interiors state that where the
existing interior floorplan does not accommodate current
technological, military, or quality of life, health, and safety
requirements, floorplan reconfiguration is acceptable if
implemented in accordance with the Guidelines. The Guidelines
for Interiors requires the retention of interior features that
are important in defining the overall historic character of the
building to the extent possible. Interior character-defining
features include columns, cornices, baseboards, crown molding,
fireplaces and mantels, stairs, and ceiling height. Before
removing interior walls that would result in a loss of historic
features, the Army or Army housing partner where the housing is
privatized will first consider options to retain those interior
walls and historic features. If, following consideration of the
economic and technical feasibility of the project, the Army or
Army housing partner where the housing has been privatized must
proceed with the removal of interior walls, they will consider

retaining historic features. When in situ preservation of such
historic features is not possible, the Army or Army housing
partner will retain such historic features through salvage and
will preserve those features through reuse on other similar
housing at that location, to the maximum extent possible.
8.0. PROCEDURE FOR BUILDING MATERIALS ASSESSMENT AND SELECTION
8.1. Building Materials Selection Procedure Summary
The Army or RCI partner where housing is privatized, will
implement the following building materials selection procedure
in support of management actions and with the assistance of
qualified historic preservation professionals, as needed. The
procedure first evaluates the character and condition of the
historic building material and considers if the repair of
historic building material is financially and technically
feasible. If repair of historic building materials is not
feasible, in-kind building materials or substitute building
materials are considered for replacement of historic building
materials with reference to the Design Guidelines for Pre-1919
Army Housing and Building Materials Guidelines and Catalog for
Pre-1919 Army Housing in appendices A and B. Section 11 of this
Program Comment ensures qualified historic preservation
professionals are available to support implementation of the
building materials selection procedure. This procedure ensures
preservation of the integrity of pre-1919 housing and historic
districts to the maximum extent possible by a thorough

consideration of character defining features, design, materials,
workmanship, feeling, and association.
8.2. Building Materials Selection Procedure
Prior to execution of a project under an applicable
management action, the following step-by-step procedure will be
implemented by the Army or by the RCI partner where housing is
privatized with the assistance of qualified historic
preservation professionals, as needed:
(1)

Characterize the historic building materials present

in terms of condition, design, material properties,
performance, safety, and presence of hazards such as
lead-based paint, asbestos, and other hazardous
materials;
(2)

Determine if historic building materials can be

repaired or if they must be replaced due to technical and
financial feasibility factors. Consider health and safety
factors, availability of historic materials and/or
skilled craftsmen, need to improve quality of life,
climate resiliency, energy efficiency. Assess financial
feasibility and determine if costs of repair will impede
full implementation of scope of the project;
(3)

If replacement is required, determine if there are

material characteristics of the historic building
materials that should be improved upon;
(4)

Identify potential in-kind building materials and

substitute building materials with reference to

appendices A and B. Compile a short list of potential inkind building materials and/or substitute building
materials;
(5)

Determine the technical feasibility of the potential

in-kind and substitute materials by evaluating quality of
life, health and safety considerations, climate
resiliency, energy efficiency, long-term durability of
materials;
(6) Determine the financial feasibility of the potential
in-kind and substitute materials through an assessment of
the project budget and consideration of materials and
labor costs to ensure full implementation of the project.
Cost assessment should also include consideration of
historic preservation tax credits; and
(7) Select the appropriate in-kind building material or
substitute building material and use the selected
material in the management action.
To ensure management actions follow the building materials
selection procedure, Design Guidelines for Pre-1919 Army
Housing, and the Building Materials Guidelines and Catalog for
Pre-1919 Army Housing, the Army Federal Preservation Officer
(FPO) will:
(1)

Ensure installations and Army privatized housing

partners with pre-1919 housing have access to the
building materials selection procedure in this Program
Comment, the Design Guidelines for Pre-1919 Army Housing

(Appendix A), and the Building Materials Guidelines and
Catalog for Pre-1919 Army Housing (Appendix B);
(2)

Ensure that qualified historic preservation

professionals are available to support the building
materials selection process and application of the
Secretary Standards for Rehabilitation as implemented
through appendices A and B, and to provide on-site
monitoring for activities under this Program Comment;
(3)

Maintain oversight of the Design Guidelines for Pre-

1919 Army Housing and the Building Materials Guidelines
and Catalog for Pre-1919 Army Housing and update the
Building Materials Guidelines and Catalog Pre-1919 Army
Housing as new applicable building materials become
available; and
(4)

Make the Program Comment, Design Guidelines for Pre-

1919 Army Housing and Building Materials Guidelines and
Catalog for Pre-1919 Army Housing publicly available on
the Army’s pre-1919 Program Comment website.
9.0. HISTORIC PRESERVATION TAX CREDITS
The Army FPO will advise its RCI privatized housing
partners that pre-1919 housing rehabilitation may be eligible
for Federal and State historic preservation tax credits.
Additional information may be found at the National Park Service
Historic Preservation Tax Incentives page
https://www.nps.gov/subjects/taxincentives/index.htm, and at the
Internal Revenue Service web page

https://www.irs.gov/businesses/small-businesses-selfemployed/rehabilitation-tax-credit-real-estate-tax-tips.
Individual states may also offer similar state-level tax
incentive programs for historic building rehabilitation and
additional information on state-level historic preservation tax
incentive programs may be obtained from the relevant State
Historic Preservation Office. It is noted that the National Park
Service approves federal tax act rehabilitation projects that
include use of substitute building materials.
10.0 ANNUAL REPORT AND ANNUAL MEETING
The Army FPO will provide an annual report to the ACHP for
the previous reporting year regarding activities under this
Program Comment. The annual report will identify any significant
issues that may have arisen while implementing the Program
Comment, how those were addressed, and how they may be avoided
in the future. The annual report will also include an assessment
of the overall effectiveness of the Program Comment in meeting
its intent, and a summary of professional assistance and
compliance monitoring activities. Annual reporting will occur
for five years beginning from the date of the ACHP Federal
Register notice of issuance of this Program Comment.
Following submission of an annual report, or upon the
ACHP’s request, the Army will schedule a meeting with the ACHP
and any other ACHP identified invitees to discuss implementation
of the Program Comment. The meeting provides an opportunity for
attendees to provide their views on the overall effectiveness of

the Program Comment in meeting its intent and purpose. Annual
meetings may take place in-person, by phone, virtually using
electronic meeting platforms, or any combination of such means.
After the first five years of annual reporting and for the
remaining duration of this program comment, information on
implementation of this program comment will be reported every
three years through the Army’s submission to the ACHP Section 3
Report to the President under Executive Order (EO) 13287
Preserve America. Similar to the annual reports, the Section 3
Report will identify significant issues that may have arisen
while implementing the Program Comment, how those were
addressed, and how they may be avoided in the future. The report
will also include an assessment of the overall effectiveness of
the Program Comment in meeting its intent.
11.0. PROFESSIONAL ASSISTANCE BY QUALIFIED EXPERTS
The Army FPO will provide for professional assistance and
monitoring of activities under this Program Comment by qualified
historic preservation experts. Professional assistance will be
available to the Army’s RCI partners by experts that meet
qualification standards published in 36 CFR Part 61 for
architectural history, architecture, historic architecture, or
history. Professional assistance will include on-site technical
support, on-call technical support, and on-site assistance
visits and monitoring.
The Army FPO will provide the contact information of the
qualified historic preservation professionals to the RCI

privatized housing partners. The technical expert support
includes review of the requirements under this Program Comment,
support for implementation of the Secretary’s Standards for
Rehabilitation and the building materials selection process, use
of appendices A and B, and monitoring and reporting on
activities implemented under this Program Comment. The Army FPO
will ensure that a minimum of five annual on-site technical
assistance and monitoring visits occur each reporting year for
installations with privatized pre-1919 housing. On-call
technical assistance will also be available to the Army’s RCI
partners via telephone, email, and virtual meetings. The
historic preservation professional assistance and on-site
monitoring activities will be reported in each Annual Report.
12.0 APPLICABILITY AND IMPLEMENTATION
The Program Comment applies to all privatized and nonprivatized pre-1919 Army housing, associated buildings and
structures, and landscape features. Where pre-1919 housing has
been privatized, Army privatized housing partners are
responsible for implementing this Program Comment and all
management actions following the procedures herein. Where
housing has not been privatized, or when there is a reversion of
leased or otherwise conveyed pre-1919 housing from a privatized
management entity back to the Army, Army installation personnel
will implement all management actions following this Program
Comment.

The Army, or RCI partner where housing is privatized will
implement the management actions in accordance with this Program
Comment in lieu of conducting individual project reviews under
36 CFR 800.4 - 800.7 or installation PAs, Memoranda of Agreement
(MOAs), or Army Alternate Procedures (AAP). This Program Comment
supersedes and replaces the requirements in all Army
installation PAs, MOAs, and AAPs pertaining to management
actions for pre-1919 housing, associated buildings and
structures, and landscape features. The Army and its privatized
housing partners will implement this Program Comment in lieu of
all PA, MOA, and AAP requirements and procedures previously
applicable to the management actions for pre-1919 Army housing,
associated buildings and structures, and landscape features. To
further clarify Program Comment implementation, existing PAs,
MOAs, and AAPs are not voided, rather the Program Comment simply
replaces the requirements applicable to pre-1919 housing
management actions in existing agreements with the requirements
of this Program Comment.
The Program Comment is a stand-alone NHPA section 106
compliance document approved by the ACHP. PAs, MOAs, and AAPs
shall not be developed or amended to “implement” the Program
Comment. The terms of the Program Comment are not subject to any
change, amendment, or further consultation through PAs, MOAs,
AAPs, or other NHPA-related actions. Changes to the terms of the
Program Comment can only be made following the amendment
procedures in section 14 this program comment.

The Army or RCI partner where housing is privatized will
also implement the Program Comment in lieu of any procedures,
environmental management plans, guidelines, reporting
requirements, Integrated Cultural Resources Management Plans,
and all other installation documents, standards, procedures, or
guidelines pertaining to pre-1919 housing, associated buildings
and structures, and landscape features.
The Army or RCI partner where housing is privatized will
not implement any further historic property identification,
evaluation, or documentation in connection with pre-1919 housing
and the management actions covered by the Program Comment. Pre1919 Army housing is adequately identified, evaluated, and
documented by the referenced mitigation documents at
https://denix.osd.mil/army-pre1919-pchh/.
Army pre-1919 housing and historic districts are the
equivalent of similar historic housing developments in the
civilian sector. As such, there is significant prior ground
disturbance in pre-1919 housing areas resulting from the
original construction the housing and subsequent improvements
over the past 100 to 200 years including overall grading for the
original construction, housing construction, construction of
associated buildings and structures, road and sidewalk
construction, installation of above and below ground utilities,
landscaping, construction of recreational structures, and other
ground disturbing actions that have occurred after original
construction. Such areas of extensive ground disturbance

associated with housing development are generally considered to
have a low probability for the presence of NRHP eligible
archeological properties. No further efforts to identify
archeological properties or other historic properties will be
conducted in connection with the implementation of Program
Comment management actions.
The Army, or RCI partner where housing is privatized will
protect known archeological resources and preserve them in place
whenever possible. If such resources must be disturbed,
mitigation measures will be undertaken by the Army. If
implementation of any management actions under this Program
Comment may cause damage, physical destruction, or change in the
physical features of all or any part of a known NRHP-eligible
archeological site or property of traditional religious and
cultural importance to Federally recognized Indian tribes or
Native Hawaiian Organizations, those effects will be addressed
by the Army following the procedures in 36 CFR 800.4 - 800.7 in
consideration of applicable principles in the ACHP Policy
Statement on Burial Sites, Human Remains, and Funerary Objects,
or by following procedures in an applicable installation PA. The
unanticipated discovery of a NRHP eligible archeological
property or human remains during implementation of management
actions will be addressed following the procedures in 36 CFR
800.13, or by following the unanticipated discovery procedures
in an applicable installation PA, and / or by following the

compliance procedures of the Native American Graves Protection
and Repatriation Act, as applicable.
The Program Comment is not applicable to pre-1919 housing,
associated buildings and structures, and landscape features that
have previously been determined to be not eligible for inclusion
in the NRHP in accordance with 36 CFR 800.4(c)(2), an applicable
NHPA agreement document, or by a determination of eligibility
pursuant to 36 CFR 63. If at a future date pre-1919 housing,
associated buildings and structures, and landscape features
previously determined not eligible for inclusion in the NRHP are
reassessed and subsequently determined to be eligible for
inclusion in the NRHP, NHPA section 106 compliance for those
properties shall occur by means of this Program Comment.
13.0. EFFECT AND DURATION
This Program Comment will remain in effect from the date of
adoption by the ACHP through December 31, 2055, unless prior to
that time the Army determines that such comments are no longer
needed and notifies the ACHP in writing, or the ACHP withdraws
the Program Comment in accordance with 36 CFR 800.14(e)(6).
Following such withdrawal, the Army will be required to comply
with section 106 through the process in 36 CFR 800.4 - 800.7, or
an applicable program alternative under 36 CFR 800.14, for each
individual undertaking formerly covered by this Program Comment.
The effective period for the Program Comment coincides with
the term of the ground leases that have been executed with the
Army’s privatized housing partners under the RCI program. Upon

termination of the ground lease, ownership of all RCI
partnership owned improvements including all housing that is
located within the boundaries of the ground lease is
automatically conveyed back to the Army. On or prior to December
31, 2055, the Army and the ACHP will meet to determine whether
to consider an extension to the term of this Program Comment.
14.0. PROGRAM COMMENT AMENDMENT AND WITHDRAWAL
The ACHP may formally amend this Program Comment after
consulting with the Army and other parties as it deems
appropriate.
14.1. Amendment by Chair, ACHP
The Chair of the ACHP, after notice to the rest of the ACHP
membership and the Army may amend this Program Comment to extend
its duration. The ACHP will notify the Army and will publish
notice in the Federal Register regarding such amendment within
30 days after their issuance.
14.2. Amendment by Executive Director, ACHP
The Executive Director of the ACHP, after notice to the
ACHP membership and the Army may amend this Program Comment to
adjust due dates and make corrections of grammatical and
typographical errors. The ACHP will notify the Army and will
publish notice in the Federal Register regarding such amendments
within 30 days after their issuance.
14.3. Other Amendments

Amendments to this Program Comment not covered by sections
14.1 or 14.2, above, will be subject to ACHP membership
approval.
14.4. Withdrawal of the Program Comment
If the ACHP determines that treatment of Army pre-1919
housing is not being carried out in a manner consistent with
this Program Comment, the ACHP may withdraw the Program Comment.
The Chair will then notify the Army and will publish notice in
the Federal Register regarding withdrawal of the Program Comment
within 30 days of the decision to withdraw. If this Program
Comment is so withdrawn, the Army shall comply with the
requirements of 36 CFR 800.4 – 800.7, or an applicable program
alternative, for individual undertakings covered by this Program
Comment.
15.0. DEFINITIONS
The following definitions apply for the purposes of the
Program Comment:
Abate or abatement means actions to eliminate, lessen,
reduce, or remove hazardous and toxic materials, and unsafe
conditions.
Army Pre-1919 historic housing is all privatized and nonprivatized Army housing, with construction completed prior to
January 1, 1919, located on an Army installation, a joint base,
or managed by the Army or by an Army privatized housing partner
including those operating under the RCI program. The terms
housing, pre-1919 housing, and pre-1919 historic Army housing

are used interchangeably in the Program Comment and mean all
Army pre-1919 historic housing, associated buildings and
structures, landscapes and landscape features, and
neighborhoods. Quarters 18 at Palm Circle, Fort Shafter, HI
constructed in 1924 is included in this Program Comment to
ensure consistent treatment of the housing in this predominantly
pre-1919 historic district.
Army pre-1919 neighborhood means a geographical area,
district, development, community, subdivision, or locality on an
installation that is characterized by and comprised
predominantly of Army pre-1919 housing, associated buildings and
structures, and landscapes and landscape features.
Associated buildings and structures includes detached
garages, carports, storage buildings, above and below ground
utilities and service systems including water, sewage, storm
water, gas, and electrical service systems, tennis courts,
pools, all buildings and structures associated with recreational
and athletic activities, playgrounds and playground equipment,
all other recreational buildings and structures, gazebos,
fencing, community centers, shelters, associated ancillary
facilities that support housing, and any and all other
buildings, structures, and objects associated Army pre-1919
housing located within Army pre-1919 housing neighborhoods.
Associated ancillary purposes that support housing
operations (reference Lease, transfer, and conveyance) refers to
the use of pre-1919 housing, buildings, and structures for

purposes such as offices including rental offices for privatized
housing partners, community centers, public safety offices that
service the housing areas, and other purposes that support
housing operations and residents of pre-1919 housing.
Climate resilient building materials means, for the
purposes of this Program Comment, modern building materials that
are used to retrofit historic buildings in order to better
withstand and recover from the negative impacts of climate
change including extreme weather events. Climate resilient
building materials help minimize those impacts on people and on
the costs to retrofit and repair historic buildings, while
preserving their historic character as much as possible.
Economic feasibility means a determination if the estimated
costs of a proposed project including consideration of the
project’s available budget, the cost of building materials,
labor, and other considerations, may jeopardize the viability
and complete implementation of the full scope and all parts of
the proposed project. The term economic feasibility is used
interchangeably with financial feasibility and cost feasibility
for the purposes of this Program Comment.
Financial feasibility see definition of economic
feasibility.
Health and safety hazards means housing that has any of the
following conditions: damaged roofs or walls; non-functional or
poorly functioning mechanical systems; unsafe common areas such
as stairs; significant rodent, insect, or mold infestations;

lead based paint exposure risks; asbestos exposure risks; risk
of exposure to other chemical or environmental hazards;
violations of health and safety codes and standards; damages due
to fire, flooding, or natural disasters; and other conditions
that present health hazards or make the housing unsafe or
uninhabitable.
Historic building materials means building materials that
were used in the initial construction of pre-1919 housing,
and/or for designated NHLs, all materials within the period of
significance.
Historic character means the same as the terms usage in The
Secretary of the Interior’s Standards for the Treatment of
Historic Properties at 36 CFR 68.
Historic designed landscapes and features are landscapes
and their features that were designed or laid out by a landscape
architect, master gardener, architect, or horticulturist
according to design principles, and retain significant
character-defining features of their original design.
Historic district means a geographically definable area
that possesses a significant concentration of historic
buildings, associated buildings and structures, and objects
united historically by plan or physical development that area
eligible for inclusion or that are included in the NRHP.
Historic property means buildings, sites, structures,
objects, and districts that are eligible for inclusion or that
are included in the NRHP.

Homes and housing units are used interchangeably for the
purposes of this Program Comment.
Imitative substitute building materials means modern,
industry standard, natural, composite, and synthetic materials
that that simulate the appearance, physical properties, and
related attributes of historic materials well enough to make
them alternatives for use when historic building materials
require replacement. The terms imitative substitute building
materials and substitute building materials are used
interchangeably for the purposes of this Program Comment and
apply to both interior and exterior building materials.
In-kind building materials means new building materials
that are identical to historic building materials in all
possible respects, including their composition, design, color,
texture, and other physical and visual properties.
Landscape features and landscapes includes the overall
design and layout of the pre-1919 housing neighborhoods
including roadway circulation systems and patterns, plantings
and landscaping, gardens, open spaces, playgrounds, recreational
landscape features including but not limited to recreational and
athletic fields, golf courses, fencing, parking areas, signage,
site furnishings, parade grounds, lighting, sidewalks and
curbing, driveways, setbacks, historic designed landscapes and
features, all visual elements and viewsheds into pre-1919
housing and neighborhoods and out from pre-1919 housing and
historic districts into other historic properties and districts,

any and all other landscape features present in pre-1919 housing
and historic districts, and any archeological properties or
features associated with pre-1919 housing construction. The term
landscape features as used in the Program Comment is inclusive
of all landscapes and landscape features in pre-1919 historic
districts.
Lease, transfer, and conveyance means the execution of
lease, transfer, and conveyance documents for lease, possession,
management, operation, and transfer of pre-1919 housing solely
for the purposes of and use as housing and associated ancillary
purposes that support housing operations. The terms of this
Program Comment apply to any such lease, transfer, and
conveyance. The RCI ground lease requires the lessee (i.e., the
limited liability corporation whose members include the Army and
the privatized housing partner) to comply with all applicable
laws and regulations. As the requirements of the Program Comment
constitute applicable law and regulation, lessee compliance with
the Program Comment is required. As new ground leases on which
pre-1919 housing is located are prepared, or as such existing
ground leases are amended, an explicit requirement to comply
with this Program Comment will be added. In the event of a
conflict or inconsistency between a lease, transfer, and
conveyance document and the Program Comment, with respect to the
obligations pursuant to sections 106 of the NHPA, the terms of
this Program Comment shall govern.

Maintenance and repair means activities required to
maintain the interior and exterior of housing, mechanical
systems, and all interior and exterior building features,
elements, and materials in an operational state, or to bring
them back to operating condition by repair or replacement of
obsolete, broken, damaged, or deteriorated mechanical systems,
features, elements, and materials on housing interiors or
exteriors.
Management actions means maintenance, repair,
rehabilitation, abatement of hazardous materials, mothballing,
and lease, transfer, and conveyance.
Mechanical systems means heating, ventilation, air
conditioning, plumbing, and electrical systems, and the
individual elements and components of each system.

Mitigation measures means any existing, new, or updated
materials or actions that serve to address, reduce, minimize, or
otherwise mitigate adverse effects on historic properties, and
may include research reports, historical documentation,
recordation, and other materials and activities.
Mothballing means an action to close and deactivate housing
and /or associated buildings and structures for an extended
period, with the intent that the property would be brought back
to a mission supporting operational status at some future time.
National Historic Landmark means historic properties
formally designated by the Secretary of the Interior under the

authority of the Historic Sites Act of 1935, that possess
exceptional value in commemorating or illustrating the history
of the United States.
Physical properties means overall size, dimensions, and
visual appearance.
Privatized housing means Army housing that has been
privatized under the Army’s Residential Communities Initiative
(RCI). The RCI operates on Army installations through the
operation of legal partnerships between the Army and private
sector developers. At each installation where RCI housing is
located, the Army conveys ownership of existing housing and
leases land to the RCI partnership. The RCI partnership with the
Army then operates and manages the conveyed housing and leased
lands for military housing purposes.
Professional assistance or qualified historic preservation
professional means assistance from an individual who meets the
Professional Qualification Standards previously published in 36
CFR 61 in the field of architectural history, architecture,
historic architecture, or history.
Rehabilitation means, in accordance with the Secretary of
the Interior’s Standards for Rehabilitation at 36 CFR 68.3(b),
the act or process of making possible an efficient compatible
use for pre-1919 housing through repair, alterations and
additions while preserving those portions or features that
convey its historical, cultural or architectural values.
Includes actions to improve energy efficiency and climate

resiliency, address obsolete, damaged, deteriorated, or
defective interior and exterior building materials and elements,
and make other changes to improve the quality of life, health,
and safety of residents. Rehabilitation includes additions,
exterior alterations, and adjacent or related new construction
allowed under the Secretary of the Interior’s Standards for
Rehabilitation (9) and (10), provided they are in accordance
with the design guidelines in appendix A.
Substitute building materials means modern, industry
standard, natural, composite, and synthetic materials that
simulate the appearance, physical properties, and related
attributes of historic materials well enough to make them
alternatives for use when historic building materials require
replacement. The terms substitute building materials and
imitative substitute building materials are used interchangeably
for the purposes of this Program Comment and apply to both
interior and exterior building materials.
Technical feasibility means an assessment of relevant
factors to determine if an action, project, or product is
suitable, practical, viable, and can be successfully
implemented. For the purposes of this program comment, technical
feasibility factors include quality of life, health, safety,
climate resiliency, energy efficiency, durability of building
materials, and compliance process time.
Texture means the visual surface appearance of building
materials.

To the maximum extent possible means implementation of
actions to the extent capable of being carried out with
reasonable effort taking into account economic and technical
feasibility.
Viewshed includes all the area visible from a particular
location, viewing point, or series of viewing points. It
includes all visual elements and surrounding points that are in
the line of sight from any location, viewing point, or series of
viewing points and excludes all points and locations that are
not visible and/or are obstructed by terrain, other natural
features, man-made features, and points beyond the horizon.
16.0. APPENDICES
APPENDIX A – DESIGN GUIDELINES FOR PRE-1919 ARMY HOUSING22
APPENDIX B – BUILDING MATERIALS GUIDELINES AND CATALOG FOR PRE1919 ARMY HOUSING23
The Design Guidelines in Appendix A and the Building
Materials Catalog in Appendix B, along with the building
materials selection procedure in section 8 are the means whereby
the Army implements the Secretary’s Standards for
Rehabilitation. The guidelines in Appendix A and B were prepared
with the assistance of qualified experts that meet qualification
standards published in 36 CFR Part 61 for architectural history,
architecture, historic architecture, or history. [As mentioned
above, due to their length, the appendices of the issued Program

From Design Guidelines for Department of Defense Historic Buildings
and Districts. Heather McDonald and Michelle Michael. August 2008. DoD
Legacy Program Project 07-382.
23 Prepared by R. Christopher Goodwin & Associates.

Comment are not reproduced here. A copy of the full Program
Comment with its appendices, and related information, can be
found at: https://www.denix.osd.mil/army-pre1919-pchh/. The
Program Comment with appendices is the document linked as
“Program Comment Pre-1919 Army Housing” under the Administrative
and Technical Documents column of the web page.]

(END OF DOCUMENT)
Authority:

36 CFR 800.14(e)

Dated: June 10, 2024

Javier Marques,
General Counsel.
[FR Doc. 2024-13045 Filed: 6/12/2024 8:45 am; Publication Date: 6/13/2024]