Sweeping Away Outdated Rules: Army Launches New Historic Preservation Framework

WASHINGTON - The U.S. Army is implementing a groundbreaking "Program Comment for Army Warfighting Readiness and Associated Infrastructure" under the National Historic Preservation Act (NHPA). This new framework modernizes the Army's approach to historic preservation, ensuring military forces remain agile and prepared while fulfilling responsibilities under Section 106 of the NHPA.

Spearheaded by Dr. David Guldenzopf, the Department of the Army’s Federal Preservation Officer, and approved by the Advisory Council on Historic Preservation in April 2026, the Program Comment sets a new national benchmark.

"This Program Comment is essential for Army transformation and modernization," said Amy Borman, Deputy Assistant Secretary of the Army for Environment, Safety, and Occupational Health. "By reforming a fragmented, outdated regulatory structure and replacing it with a single, cohesive set of modern procedures and standards, we enable our forces to move and transform at mission speed while maintaining a practical, respectful stewardship of our heritage."

From a Localized Approach to a Unified Program

Previously, the Army managed its 200,000 historic properties through a series of 115 separate local installation-specific compliance agreements. Over time, many of these agreements became outdated, and their complex, project-by-project review processes caused delays in Army readiness activities. This localized approach also applied museum-level preservation standards to utilitarian military infrastructure and resulted in inconsistent treatment for similar historic Army buildings across different states. The new Program Comment resolves these issues by establishing a consistent, Army-wide compliance framework and standardized preservation guidelines that are applied across all installations.

As Dr. Tim Schilling, Cultural Resources Program Manager for the Installation Management Command noted "By eliminating unnecessary administrative processes and applying uniform preservation standards, the Program Comment frees up critical resources to better support on-the-ground cultural resource management and mission needs.”

Key Features of the Army Program Comment

A Unified Framework: A new "military landscape" concept treats installations as dynamic environments shaped by the readiness mission, providing a realistic basis and appropriate context for preservation activities.

Strategic Stewardship: In a major evolution of historic preservation practice, the Army has established three highly significant National Mitigation Areas (NMAs). NNMAs are designated locations where the Army has a commitment to long-term stewardship of historic properties. These areas contain a high concentration of valuable historic, prehistoric, and traditional cultural properties. NMAs are at a landscape scale and are historic preservation mitigation banks functioning as a compensatory and alternative mitigation option for the Army. The NMAs are Carlisle Federal Indian Boarding School National Monument at Carlisle Barracks, PA; Castner Range National Monument at Fort Bliss, TX; and Kūkaniloko Conservation Easement, Oahu, HI.

Tiered Management: A tiered system prioritizes preservation efforts based on the significance of the property, focusing resources on National Historic Landmarks and sites of traditional religious and cultural importance to Federally recognized Tribes and Native Hawaiian Organizations (NHO).

Modernizing WWII and Cold War Era Buildings(1941-1989): Properties from this era comprise over 90% of the Army's historic building inventory. By leveraging decades of existing preservation research and documentation, the Program Comment fully satisfies all Section 106 requirements for the entire portfolio. Army commanders can now rapidly adapt, renovate, or replace these facilities without the redundant bureaucracy.

Standardized Treatment for Pre-1941 Buildings: The Program Comment empowers installation commanders to modernize facilities rapidly and cost-effectively by establishing standardized guidelines for pre-1941 buildings. This includes authorizing the use of durable, modern imitative substitute materials on building exteriors and excluding interior renovations from preservation review due to extensive past alterations.

Tribal Sovereignty: The Program Comment corrects a structural flaw in current Section 106 regulations that inappropriately subordinates Tribes and NHOs to state-level agency decisions. It now mandates direct Army-to-Tribal and NHO consultation without state agency involvement. "We are correcting a fundamental imbalance," explained Ms. Mary Schmidt, Army Senior Tribal Laision. "By establishing this as our absolute standard, we are ensuring Tribes and Native Hawaiian Organizations have a direct voice in decisions regarding their heritage."

Mr. Dave Crowley, award-winning Cultural Resource Manager for U.S. Army Garrison Hawaii, explained how the Program Comment effects his work on the ground overall: "This Program Comment turns policy into meaningful action. It removes process barriers to expedite the military mission while shifting us from piecemeal reviews to holistic cultural resource management."

The Army is committed to transparency and will publish annual reports and host annual meetings on activities covered by the Program Comment. This new landmark approach allows the Army to more effectively manage its historic properties while adapting its infrastructure to meet modern defense challenges.

For more information, please visit the official website:.