Department of Defense-wide Program Comment for NHPA Compliance 20 March 2006 Susan Thompson Preservation Branch Chief Base Operations Support Division U.S. Army Environmental Center 1of 26 021400RMAR2006
Background The Department of Defense is facing a major compliance challenge in the next 20 years, as more than 100,000 buildings will reach the 50-year age mark more than doubling the current number of properties subject to the National Historic Preservation Act (NHPA) At the same time, there are a number of initiatives in the near future (Privatization, BRAC, etc.), as well as day-to-day operations, that will affect large number of properties Pursuing project-by-project compliance for these projects is not cost effective or efficient 2of 26 021400RMAR2006
Rationale In the next 20 years, tens of thousands of Cold War era buildings will be reaching 50 years of age Many of these buildings are utilitarian, or built to standardized plans Building-by-building NHPA compliance for these properties would be a poor use of installation staff resources, as well as an enormous burden on SHPO offices Completing action for UPH will allow DoD to improve Quality of Life for Soldiers, Sailors, and Airmen, Marines Completing action for Ammunition Storage facilities will allow DoD to support war-fighting requirements Completing action for Army Ammunition Production Facilities and Plants will allow the Army to modernize production facilities to support warfighting requirements 3of 26 021400RMAR2006
DoD Buildings & National Historic Preservation Act All data as of 30 Sep 05 Army Navy (incl. Marine Corps) Air Force DoD Total (incl. Marine Corps and WHS) Total DoD Buildings: US/ Territories 153,023 95,495 96,415 344,950 Total currently over 50 years old subject to NHPA 62,587 41% 28,134 29% 18,870 20% 109,595 32% Total over 50 years old in 10 years (2015) 90,494 (27,907 added) 59% 51,682 (23,548 added) 54% 49,852 (30,982 added) 52% 192,032 (82,437 added) 56% Total over 50 years old in 20 years (2025) 104,034 (13,540 added) 68% 64,138 (12,456 added) 67% 61,668 (11,816) 64% 229,846 (37,814 added) 67% Note: Does not include projected new construction, demolition or other disposal (e.g. BRAC) activities. 4of 26 021400RMAR2006
Program Comments DoD policy is moving towards the use of programmatic NHPA approaches to address depart-wide compliance issue, and has been pursing Program Comments with the Advisory Council on Historic Preservation to address compliance responsibilities for management of three property types A Program Comment fulfills compliance requirements for an entire category of undertakings such as renovation, demolition, or transfer, sale or lease from Federal ownership for a particular building type Eliminates need for installation-level NHPA compliance, mitigation The DoD is seeking Program Comments on management actions for three types of buildings representing approximately 45,000 buildings The Program Comment process was previously used by the Army to cover compliance requirements for more than 19,000 Capehart and Wherry era Army family housing buildings. The Navy and Air Force completed a follow-on action to address their Capehart-Wherry housing. 5of 26 021400RMAR2006
Increase in Army Buildings Subject to NHPA in Next 20 Years Number of Army Properties 50 Years or Older 95000 85000 75000 65000 55000 45000 35000 25000 2005 2010 2015 2020 2025 Number of Properties Subject to NHPA Year 6of 26 021400RMAR2006
Program Comments Significantly Reduce Buildings Subject to NHPA in Next 20 Years Number of Army Buildings Subject to NHPA* 95000 85000 75000 65000 55000 45000 35000 25000 2005 2010 2015 2020 2025 Year NHPA Compliance Addressed Ammo Plants Ammo Storage UPH Capehart-Wherry Remaining Bldgs Subject to NHPA *Buildings 50+ Years Old 7of 26 021400RMAR2006
Program Comment Process Secretariat notifies ACHP of intent to seek Program Comment DoD initiates public participation requirement through NEPA process Information meetings with stakeholders (NCSHPO and NTHP) Secretariat provides ACHP with formal request for Program Comment, a mitigation strategy, and a summary of public comments ACHP conducts consultation with stakeholders ACHP votes to issue Program Comment DoD publishes final EA/FONSI and adoption of Program Comments Each Service is responsible for completing its own mitigation actions mitigation to be completed at HQ level 8of 26 021400RMAR2006
Three Property Types Cold War era (1946-1974)Unaccompanied Personnel Housing World War II and Cold War era (1939-1974) Ammunition Storage Facilities World War II and Cold War era (1939-1974) Army Ammunition Plants 9of 26 021400RMAR2006
Cold War Era Unaccompanied Personnel Housing Rolling-pin Barracks, Ft. Hood, (1969) The DoD has approximately 5,000 Unaccompanied Personnel Housing (UPH) buildings, more commonly known as barracks, from the 1946-1974 Cold War period The Cold War required a large standing military force of unprecedented size. The military was then faced with the problem of housing these personnel; accordingly many barracks and family housing structures were built during this period 10 of 26 021400RMAR2006
Cold War Era Unaccompanied Personnel Housing These buildings have reached, or will soon reach, the fifty-year age mark, at which point they become subject to the National Historic Preservation Act Current initiatives, including actions under the Army Barracks Master Plan, and Privatization, will require the DoD to meet compliance responsibilities under NHPA for these buildings The barracks were built in a semipartitioned style, but current living standards require individual or two-person rooms. All UPH will be upgraded to meet these standards. Hammerhead Barracks, Ft. Bragg (1955) 11 of 26 021400RMAR2006
Cold War Era Unaccompanied Personnel Housing The US Army Environmental Center has already completed a historic context on Cold War era UPH. The context showed that UPH from the 1946-74 era tend to fall in several categories of standardized plans. This standardization is one reason why a Program Comment is particularly appropriate for these properties H-Style Barracks, Fort Benning, (1955) The three most widespread types of standardized plans include hammerhead, rolling pin, and H-style. Hammerhead and H-style barracks consolidated troop housing, dining facilities, and administration facilities in one building 12 of 26 021400RMAR2006
World War II and Cold War Era Ammunition Storage Facilities The DoD has more than 29,000 WWII and Cold War Era ammunition storage facilities (1939-74), which fall into two categories: underground and aboveground Interior of an Explosives Storage Magazine Hollow clay tile aboveground magazine 13 of 26 021400RMAR2006
World War II and Cold War Era Ammunition Storage Facilities Army Standard Igloo (WWII) Modern ammunition storage facilities reflect the lessons learned from the 1926 Lake Denmark disaster, in which ammunition bunkers exploded in a chain reaction There were 6 standardized underground igloo designs used during WWII, and several aboveground magazine types. The Cold War required minor modifications to existing designs to accommodate newer technology Stradley magazine (Cold War). Note similarity to the WWII model 14 of 26 021400RMAR2006
World War II and Cold War Era Army Ammunition Plants The Army has approximately 11,000 ammunition production facilities and properties on Army Ammunition Plants from the WWII and Cold War eras (1939-74). Future actions, including planned excessing actions and Base Realignment and Closure activities, have the potential to affect these properties Due to the industrial nature of the property, and hazardous contamination from the production process, there are limited re-use possibilities for these properties Explosives Manufacturing Plant, Holston AAP 15 of 26 021400RMAR2006
World War II and Cold War Era Army Ammunition Plants Most Army Ammunition Plants were built during World War II as Government-Owned ContractorOperated (GOCO) Ordnance works The Ordnance Works were built as complete installations, including not only ammunition production facilities, but also the facilities (administration, storage, housing) needed to support them Acid Area, Joliet AAP Though the technology used in the production facilities was significant, it cannot be taken out of context of its support structure US ammunition production capacity was key to the Allied victory in WWII 16 of 26 021400RMAR2006
What will be covered? Categories of undertakings: ongoing operations, maintenance and repair, rehabilitation, renovation, mothballing, cessation of maintenance, new construction, demolition, deconstruction and salvage, remediation activities, and transfer, sale, lease, and closure. The Program Comments will solely apply to the property types identified. Accordingly, it will not apply to archeological historic properties, including those of traditional religious and cultural significance to Federally-recognized Indian Tribes or Native Hawaiian organizations. The Program Comments will not apply to UPH or Ammunition Storage Facilities in National Register of Historic Places districts where the those properties a contributing element of the district and the proposed undertaking has the potential to adversely affect the historic district. This exclusion does not apply to historic districts that are made up solely the identified property type; in those cases the Program Comment would be applicable to such districts. 17 of 26 021400RMAR2006
What will be covered? An installation with an existing Section 106 agreement document in place that addresses the identified property types can choose to: continue to follow the stipulations in the existing agreement document for the remaining period of the agreement; or seek to amend the existing agreement document to incorporate, in whole or in part, the terms of the Program Comment; or terminate the existing agreement document, and re-initiate consultation informed by the Program Comment if necessary. All future Section 106 agreement documents developed by the Military Departments related to the undertakings and properties addressed in the Program Comments shall include appropriate provisions detailing whether and how the terms of the Program Comments apply to such undertakings. 18 of 26 021400RMAR2006
What will be covered? Unaccompanied Personnel Housing All buildings and structures that were designed and built as UPH in the years 1946-1974, regardless of current use. All buildings and structures with the DoD Category Group (2 digit) Code of 72, Unaccompanied Personnel Housing, in the Military Service s Real Property Inventory. 19 of 26 021400RMAR2006
What will be covered? Ammunition Storage Facilities This action will include all buildings and structures that were designed and built as ammunition storage facilities within the years 1939-1974, regardless of current use. All buildings and structures with the DoD Category Group (2 digit) Code of 42, Ammunition Storage, in the Military Service s Real Property Inventory. 20 of 26 021400RMAR2006
What will be covered? Army Ammunition Plants and Production The proposed action will cover approximately 10,933 buildings and structures built between 1939 and 1974 at 28 AMC installations. All World War II and Cold War Era ammunition production facilities and plants and associated buildings, structures, and utilities In addition, it will cover 5,421 associated ammunition storage buildings at AAPs that are also covered by the DoD-wide Program Comment for Ammunition Storage Facilities. The total number of properties covered is 16,354. A list of all these properties will be provided once Program Comments are authorized by the ACHP 21 of 26 021400RMAR2006
Cold War Era UPH Mitigation DoD Proposed Mitigation Army modifies its existing context to provide a publicly available version The Departments of the Navy and Air Force write supplemental contexts similar to the Army s for their own inventories The Departments of the Navy and Air Force will also document a sample of their UPH inventory Additional Stakeholder Proposed Mitigation All military departments should encourage adaptive reuse of the properties when feasible, as well as the use of historic tax credits by private developers under lease arrangements Departments should also incorporate adaptive reuse and preservation principles into master planning documents and activities 22 of 26 021400RMAR2006
World War II and Cold War Era Ammunition Storage Facilities - Mitigation DoD Proposed Mitigation Army will expand its current context (1775-1945) to include the Cold War Navy and Air Force will write supplemental context similar to that of the Army Army will also document ammunition storage facilities at nine installations (6 WWII and 3 Cold War) The Departments of the Navy and Air Force will document a sample of their Ammo Storage inventory The Military Departments will provide a list of all properties covered by the program comment, by state, to stakeholders. Additional Stakeholder Proposed Mitigation Military departments should incorporate adaptive reuse principles into master planning documents, and encourage developers to use historic tax credits 23 of 26 021400RMAR2006
World War II and Cold War Era Army Ammunition Plants - Mitigation Army Proposed Mitigation Expand existing WWII Army Ammunition Plants context and documentation of nine installations to cover the Cold War era, and document two more installations that have significance under the Cold War Documentation includes an installation history, and the collection of historic photographs and plans The Army will provide a list of all properties covered by the program comment, by state, to NCSHPO and ACHP Additional Stakeholder Proposed Mitigation The Army should also develop public information materials that outline the ammunition production process, including ammunition storage 24 of 26 021400RMAR2006
Timeline to Date Oct 31, 2003 HQDA informed ACHP of its intent to seek Program Comments for WWII Army Ammunition Plants, WWII and Cold War era Ammunition Storage Facilities, and Cold War era Unaccompanied Personnel Housing (UPH) Nov 2003 DoD elects to pursue the Ammo Storage and UPH Program Comments across all services Oct 26, 2004 Notice of Availability of EA for the three programmatic actions published in the Federal Register Mar 22, 2005 Meeting held with NCSHPO and National Trust to discuss properties and mitigation strategies Jun 21, 2005- Follow-up meeting held with NCSHPO and National Trust to finalize mitigation proposal Aug 2005 - Program Comments requests staffed to DoD for coordination and transmittal to ACHP Mar 2006 DoD provides ACHP with formal request for Program Comments, a mitigation strategy, and a summary of public comments 25 of 26 021400RMAR2006
Program Comment Process Remaining Steps ACHP conducts consultation with stakeholders anticipated Mar-May 2006 ACHP vote to issue Program Comments anticipated May 2006 DoD publishes final EA/draft FONSI and adoption of Program Comments anticipated Aug 2006 Each Military Department will complete its own mitigation actions HQ level mitigation 26 of 26 021400RMAR2006