CaseStudy:Fort Hood Army Alternate Procedures implementation

Fort Hood, located about 70 miles north of Austin, Texas, has developed a plan under the Army Alternate Procedures to streamline Section 106 compliance. The plan will allow Fort Hood to identify, evaluate, determine effects, and mitigate effects, if needed, to historic properties through internal processes without project-specific review by stakeholders. Fort Hood submitted its plan for ACHP certification in January 2010.

Details
The plan under the Army Alternate Procedures (AAP) is known as a Historic Properties Component (HPC). The HPC is composed of a series of Standard Operating Procedures (SOP), each addressing a particular part of the Section 106 compliance process. By following the agreed-upon procedures in each SOP, Fort Hood will conduct all steps of the Section 106 process internally, and will report on its actions to consulting parties in annual meetings. Notification of adverse effects to stakeholders will occur primarily under the National Environmental Policy Act process, during which stakeholders have an opportunity to comment.

Fort Hood originally planned to submit the HPC for ACHP certification in February 2009. This submittal was delayed, however, when the Texas State Historic Preservation Office (SHPO) declined to sign the plan until several concerns had been addressed. It was then further delayed due to staff changes both at Fort Hood and the SHPO. The SHPO signed the HPC in December 2009, and Fort Hood submitted it to the ACHP for certification on January 11, 2010. The ACHP has conditionally certified the HPC, requiring Fort Hood to modify one SOP to be in accordance with the requirements of the AAP. Fort Hood has 60 days to make the change and resubmit; the final certification is expected in April 2010.

The Army and the ACHP worked together for several years to develop the AAP, which the ACHP approved for use by Army installations in 2001. Fort Hood notified the ACHP that it would be pursuing participation in the AAP in late 2002. Upon final certification, it will join Fort Sam Houston and Fort Benning in operating under the AAP. The goal of the AAP is to increase the efficiency of Section 106 compliance at installations by tailoring it to the installations’ existing internal processes. The AAP also encourages installations and their consulting parties to work together to manage historic properties proactively, rather than on a reactive case-by-case basis.