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Conducting Section 106 Reviews under BRAC. Charlene Vaughn Advisory Council on Historic Preservation. ACHP History with the BRAC Program. MOAs and PAs for closed facilities Focused on buildings Little attention to archeology Stakeholder participation limited to local communities (LRAs)

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conducting section 106 reviews under brac

Conducting Section 106 Reviews under BRAC

Charlene Vaughn

Advisory Council on

Historic Preservation

achp history with the brac program
ACHP History with the BRAC Program
  • MOAs and PAs for closed facilities
    • Focused on buildings
    • Little attention to archeology
  • Stakeholder participation limited to local communities (LRAs)
  • Mitigation plans resulted in retention and reuse
major lessons learned from previous brac rounds
Major Lessons Learned from Previous BRAC Rounds
  • Consult early in the process
  • Improve NEPA coordination
  • Broaden stakeholder participation
  • Recognize complexities of covenants
  • Consider future remediation
  • Clarify roles and responsibilities for post-agreement reviews
new approaches to 106 review for brac 2005
New Approaches to 106 Reviewfor BRAC 2005
  • Streamline reviews through program alternatives [36 CFR § 800.14(a) – (e)]
  • Prepare baseline information early
  • Identify standard mitigation measures for various types of conveyances
  • Develop ACHP policy regarding remediation impacts on redevelopment options
  • Develop tribal consultation protocols
impact to historic properties closure vs realignment
Impact to Historic Properties:Closure vs. Realignment
  • Closure requires consideration of discrete, more immediate preservation issues
  • Realignment should focus on
    • Section 106 and Section 110 of NHPA
    • Long-term management
    • Indirect effects on historic properties
role of consulting parties
Role of Consulting Parties
  • Involvement of State and local preservationists is important
  • Role of developers should be addressed
  • Consider other parties, besides SHPOs to become covenant holders
  • Tribal consultation must be on a government-to government basis
dod achp collaboration improvements to section 106 reviews
DoD & ACHP Collaboration:Improvements to Section 106 Reviews
  • ACHP staff participates in DoD BRAC work groups
  • ACHP membership involved in program alternatives
  • ACHP established DoD BRAC task force to assist DoD
  • ACHP and DoD must consider new strategies for streamlining BRAC review process
contact information
Contact Information

For further information, contact:

Charlene Vaughn

Assistant Director

Office of Federal Agency Programs

Advisory Council on Historic Preservation

1100 Pennsylvania Ave., NW #803

Washington, DC 20004

Telephone: 202-606-8533

Email: cvaughn@achp.gov