PICATINNY ARSENAL, N.J. - U.S. Army Cultural Resource Managers (CRMs) representing 13 U.S. Army Installation Management Command (IMCOM) installations convened at Picatinny Arsenal for a three-day training course on April 9-11 organized by the Army Environmental Command (AEC).
The meeting’s focus was on the implementation of Army Alternate Procedures (AAP) and its significance for CRMs across various IMCOM installations.
AAP is a streamlined management process tailored to the agency’s decision-making process. Its goal is to reduce administrative burdens and costs, allowing qualified staff to respond to projects or undertakings more quickly when addressing project needs. The program alternative was first developed in 2000, and then amended in 2004, by the Department of the Army and the Advisory Council on Historic Preservation (ACHP). Today, all Army Section 106 program alternatives are initiated and once implemented by the ACHP, oversaw by the Department of the Army’s Federal Preservation Officer, Dr. David Guldenzopf.
AAP is an alternative process that fulfills the substantive requirements of Section 106 of the National Historic Preservation Act (NHPA).
“AAP establishes minimum requirements for compliance and installations are encouraged to pursue customizable agreements tailored to meet the needs of the installation and their consulting parties, creating an overall streamlined process for NHPA compliance,” Winston said.
To adopt AAP, an installation’s garrison commander and CRM team work closely with the ACHP and the appropriate State Historic Preservation Office (SHPO), Federally recognized Indian Tribes, and identified consulting parties on the development of a Historic Properties Component Plan (HPC); a management plan and agreement document for how an installation will manage its known and unknown historic properties.
“Even though this Army Alternate Procedures process has been in place for a number of years, there are only three U.S. Army installations using it right now, and Picatinny Arsenal is one of them,” said Osmar Alaniz, a cultural resources subject matter expert (SME), for the U.S. Army Environmental Command, part of IMCOM headquarters out of Joint Base San Antonio, Texas.
There has been an initiative across the Army to transition away from traditional agreement documents (Programmatic Agreements and Memorandum of Agreements) to conducting National Historic Preservation Act (NHPA) activities programmatically through program comments or have more installations consider the use of and then implement AAP.
Picatinny Arsenal CRM Rachael Winston facilitated the training which included representatives from Fort Detrick, Fort Huachuca, Fort Leonard Wood, Fort Moore, Fort Riley, Fort Sill, Yakima Training Center, Presidio of Monterey, Fort Leavenworth, USAG Hawaii, USAG Hawaii Pōhakuloa Training Area, USAG Yuma Proving Ground, and West Point (United States Military Academy).
The primary aim of this training is to provide awareness among Army CRMs regarding the nuances of implementing AAP. It also served as an educational opportunity facilitated by AEC to enhance the overall understanding of AAP among Army CRMs.
“My hope is to fundamentally prepare installations to pursue AAP agreements across IMCOM and to eventually reach Army Reserves and Army National Guard units,” Winston said.
The training curriculum at Picatinny included both classroom instruction and practical field exercises, offering participants an immersive learning experience. Participants visited three of Picatinny’s five National Register of Historic Places eligible historic districts to learn about their history and importance to the Army, two archaeological sites, and as well as areas currently undergoing mitigation measures for undertakings reviewed during the Section 106 process via the installation’s HPC.
“We have an excellent program and are a great small scale case study to show how the nuts and bolts of the program functions,” Winston said.
Picatinny Arsenal was awarded the 2015 Secretary of Defense Environmental Award for Cultural Resources Management, Small Installation. The award was due in part to its adoption of the AAP, its streamlining compliance efforts in cultural resources management, and improving its consultation on and management of its historic properties.
“We (Picatinny) have participated in the program since 2012 and the cultural resources program won the Army and DoD Cultural Resources (CR) Award for the program’s implementation,” Winston said.
Picatinny boosts 187 historic properties eligible for listing in the National Register of Historic Places (NRHP) include: seven archaeological sites; however, presently U.S. Army Garrison Picatinny Arsenal has an additional 57 archaeological sites more than 50 years old that are not yet evaluated for eligibility to be included in the NRHP and required further diagnostic testing. They also include 41 buildings, 126 structures, eight objects, and five historic districts:
- Administration and Research Historic District (circa 1880-1945)
- Ordnance Testing Area Historic District (1928-1948)
- Naval Air Rocket Test Station (NARTS) Test Area D Historic District (1946-1989)
- Army Rocket Test Area Historic District (1946-1989)
- Lake Denmark Naval Ammunition Depot Historic District (1891-1946)
Picatinny Arsenal Environmental Affairs Division reviews thousands of projects annually that could potentially impact environmental resources include those of cultural significance. On average approximately 400 to 500 of those projects require additional and more detailed reviews to assess potential adverse effects to cultural resources.
“By working with our consulting parties to establish an internal decision-making process that Picatinny can use to conduct these reviews, we have eliminated the need to have our consulting parties review these projects individually which previously had a time and manpower cost of about six to nine months per project not just to the Army but our consulting parties, often creating project delays,” Winston said.
“When evaluating the effectiveness of Picatinny’s established decision-making process via AAP, typically we contact our consulting parties between five and 10 times a year to execute its monitoring and review standard operating procedure due to adverse effects in addition to our annual report. Each time we conduct a review and monitoring request via our standard operating procedure, we have been able to cut down the project review time from six to nine months per project to approximately 30 to 45 days,” she said.
“In most recent years, due to the execution of best management practices and the use of project alternatives, also standard operating procedures within our decision-making process, we have been able to reduce the number of adverse effects executed by the Army and external contacts to consulting parties to less than five times per year. The administrative burden associated with the Section 106 process has been substantially reduced not just for the Army but to the SHPO, Federally recognized Indian Tribes, and other consulting parties we work with. Presently, Picatinny is undergoing consultation for the recertification of its third agreement for its use of AAP and anticipates completing that process in December 2024.”
Installation officials are expected to be collaborative with their SHPO, Federally recognized Indian Tribes, Native Hawaiian organizations, and other consulting parties to foster positive stewardship of the cultural resources managed by the U.S. Army.
Those interested in pursuing AAP agreements should reach out to Osmar Alaniz Cultural Resources SME at AEC to be given assistance in starting the AAP development process.
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