CaseStudy:Fort Sam Houston National Cemetery Programmatic Agreement expansion and improvements

The National Cemetery Administration of the Department of Veterans Affairs (VA) acquired 40 acres of undeveloped land adjacent to the existing Fort Sam Houston National Cemetery in San Antonio, Bexar County, Texas. VA plans to develop this land for burials and to make improvements to the existing cemetery: repair infrastructure, construct new administration buildings, renovate the existing historic administration building, complete road improvements, and install new signage. The expansion and improvements will take place in two phases.

Details
VA, the Texas State Historic Preservation Office (SHPO), and the Advisory Council on Historic Preservation (ACHP) participated in the consultation resulting in a Programmatic Agreement (PA). VA initiated Section 106 consultation with the Texas SHPO having already acquired the 40-acre parcel and having developed 95 percent-complete design plans. When the SHPO indicated that more time was needed to complete consultation, VA responded that there were actually two undertakings: the development of the new parcel and the improvements to the existing national cemetery. The Texas SHPO requested ACHP involvement to assist VA in interpreting the definition of undertaking in this situation. The PA was executed on February 18, 2009.

The PA addresses both phases of the undertaking, enabling VA to proceed with development of the 40-acre parcel in the short-term while providing a process for further consultation regarding improvements within the historic cemetery to take place in coming years. The PA provides a clear definition of the two phases and provides opportunities for the SHPO, tribes, consulting parties, and the public to participate in the consultation regarding phase two.

In this case it was possible to use a programmatic approach for the two-phase undertaking to complete the Section 106 consultation in an expedited manner. However, the ACHP and VA’s Federal Preservation Officer continue to work together to educate agency officials regarding the requirements of Section 106 and the imperative to begin consultations early in the planning process.