The public comment period for the Advisory Council on Historic Preservation’s Program Comment on Accessible, Climate-Resilient, Connected Communities, aimed at accelerating timelines for historic preservation reviews, ends October 9.
If adopted, the change would influence billions of dollars of investments, including for federal and federally-funded building upgrades, bike and transit infrastructure, and housing, including one million units in the Department of Housing and Urban Development portfolio, one million units of housing in the Department of Defense portfolio, as well as federal investments in private housing.
The ACHP oversees a process called Section 106, pursuant to the National Historic Preservation Act, that requires federal agencies to take into account the impact of their actions on historic properties. Those actions can include projects that are directly undertaken by an agency, as well as projects that are funded, licensed, permitted, or otherwise assisted by the federal government. There’s a broad range of actions that are covered under Section 106, upwards of 120,000 projects across the federal government every year.
Urban Land recently spoke with Sara Bronin, chair of the Advisory Council on Historic Preservation, about the Biden Administration’s efforts to accelerate project permits and reviews involving historic buildings.
UL: What does the ACHP’s proposed action entail?
Sara Bronin: The action that the ACHP just proposed covers three different aspects of the built environment that we addressed in our recent policy statements on housing and on climate change. In these statements, we indicated that we would evaluate and update the Section 106 process, which requires federal agencies to take into account the effects of their actions on historic properties.
We developed the proposed Program Comment on Accessible, Climate-Resilient, Connected Communities as an alternative compliance mechanism for the standard Section 106 review process, to advance those principles in our policy statements that push for a better housing and climate response, and to promote historic preservation by encouraging the reuse of buildings and by facilitating the types of transportation infrastructure that are most compatible with our historic neighborhoods.
UL: What are the three different aspects of the built environment that the program comment covers?
Bronin: The first part of the program comment covers housing, and it’s intended to encompass both housing conversions in public and private buildings, as well as the rehabilitation of existing housing, including energy efficiency upgrades, abatement of hazardous materials, and larger-scale interior renovations.
The second part of the program comment addresses what we are calling “climate-smart buildings.” It focuses on those actions that federal agencies may take or may fund in buildings that would make those buildings more climate-resilient or would reduce their greenhouse gas emissions. One reason the climate-smart buildings portion of the program comment is really important is that billions in new federal funding, including the Greenhouse Gas Reduction Fund and the Inflation Reduction Act, would be subject to our agency’s review process. The program comment aims to clearly articulate the ways in which historic buildings can benefit from these decarbonization investments.
The third part of the program comment on transportation, also involves tens of billions of dollars in funding from the federal government for local, state, and federal projects that aim to promote what we call “climate-friendly transportation.” Walking, biking, micromobility, and transit infrastructure are the types of transportation that are overall better for our environment than the most dominant mode, which is the use of individual vehicles.
UL: This would impact public housing and federally funded buildings?
Bronin: Yes, it would affect all public housing, including not just the one million units in the Department of Housing and Urban Development portfolio, but also the million units of housing in the Department of Defense portfolio and other federal agency–operated housing, as well as federal investments in private housing.
UL: In what ways will the proposed measure facilitate integration of renewable energy, like panels
Bronin: For the first time, the program comment would establish a clear set of rules for how solar panels can be integrated into historic buildings. It would enable federal agencies to site solar panels on the rooftops of buildings subject to certain conditions. And it would also enable solar panels to be installed in visible locations, where a qualified professional has confirmed that doing so would not adversely affect historic fabric.
UL: What are the implications that these changes could have for future investments and climate-smart infrastructure and housing initiatives?
Bronin: The proposal has the potential to accelerate the deployment of federal investments in solar panels, energy efficiency improvements such as insulation, building control systems, and mechanical systems, as well as accelerating investments in making our buildings more climate resilient through the installation of green infrastructure and other site work.
UL: How many people or households could this potentially benefit?
Bronin: Over the duration of the program comment, it could benefit potentially tens of millions of households because it is written to apply broadly to a large range of actions relating to housing and to building improvements across all federal agencies.
As the proposal goes through the consultation and public comment process, we’re hoping to see robust engagement by a wide variety of stakeholders to help illuminate exactly how this program comment might be used to benefit communities and to propose amendments where the draft can be improved.
UL: What does the public need to understand about next steps, next actions?
Bronin: The public comment period for this proposal will end on October 9. I strongly encourage anybody who is working to invest in historic places and to improve their communities to comment, so we can ensure that our historic preservation goals are met alongside our housing and climate goals.
