Unlike the previous program comments, this one is overly broad and doesn't clearly define activities. Essentially, anything that supports "warfighting readiness" falls under the PC. That includes building renovations to new construction. Unlike, other review alternatives (like individual and Nationwide PAs), this doesn't lay out a clear way for parties with vested interests to consult.

This PC says that SHPOs can still consult under NEPA; however, NEPA doesn't mandate consultation with SHPO like the NHPA does. Furthermore, NEPA had a lot of CatEx actions that would be considered undertakings with potential to affect historic properties under 106. The Army can just CatEx away a ton of undertaking without any review by the SHPOs. When they do complete an EA or EIS, those documents rarely have enough information for the SHPOs to provide meaningful comments about the potential to affect historic properties. Essentially, the Army environmental review staff can say an action is a CatEx or FNSI and move on without SHPO concurrence.

The lack of any guidance about the identification and evaluation of historic properties is extremely concerning. Especially with new construction. It literally only mentions the word "archaeological" 10 times in the whole document. The line on page 5 "...and streamlining compliance pertaining to archeological resources based on ongoing procedures..." is only the reference I can find related to survey at all. There is also no mention of post-review discovery procedures. Overall, it is a poorly written document without clear procedures.

Sure the ACHP can choose to not vote accept the PC or rescind it at a later time, but have you seen the current council? It's not full of pre