On Friday, July 18, the Vice Chair of the Advisory Council on Historic Preservation (ACHP) circulated a proposal that would fundamentally alter—and, in many respects, dismantle—the federal Section 106 review process as it has existed for decades. The ACHP is expected to vote on the proposal this Friday. If approved by a majority of Council members, it will be released for a 30-day public comment period. 

Section 106 of the National Historic Preservation Act is the federal review process that requires agencies to consider the effects of federally funded, licensed, or permitted projects on properties listed in or eligible for the National Register of Historic Places. It ensures that preservation organizations, local communities, Tribes, State Historic Preservation Offices, and other consulting parties have an opportunity to participate in decisions affecting our nation's historic resources. 

Docomomo US has participated as a consulting party in numerous Section 106 reviews involving nationally significant Modern resources, including the Hirshhorn Museum in Washington, DC, the Weyerhaeuser Corporate Headquarters in Federal Way, Washington, and the Chet Holifield Federal Building in Laguna Niguel, California. We are currently consulting on the proposed redesign of Pennsylvania Avenue in Washington, DC, and advocating for the J. Edgar Hoover FBI Building, which was determined ineligible for listing in the National Register prior to it reaching the 50-year threshold. 

Docomomo US strongly opposes the proposed changes to the Section 106 regulations, which would significantly reduce public participation, weaken the role of consulting parties, and shift greater decision-making authority to federal agencies.

We encourage our members to contact their representatives in Congress and submit comments to the ACHP during the public comment period. 

Docomomo US will be an active participant in efforts to oppose these changes and preserve a meaningful Section 106 process. We are grateful for the leadership and collaboration of our colleagues at Cultural Heritage Partners, the National Trust for Historic Preservation, the National Conference of State Historic Preservation Officers, and many other preservation organizations working together on this important issue. 

How You Can Help:

• Contact your congressional representatives in the House and Senate

• Stay tuned for the results of the ACHP vote on Friday July 24, then follow guidance for submitting public comment

• Attend the National Trust webinar on July 30

• If you know of a project where federal agencies are already cutting corners in the Section 106 process, contact Cultural Heritage Partners confidentially on Signal (marionchp.106) or by email.

   

To support our advocacy efforts for Section 106 and all of the other modern sites we champion, please consider a donation and select “Advocacy Fund” from the drop-down menu.

Sources:

“ACHP Proposes New Regulations that Devastate Protections for Historic Properties,” Cultural Heritage Partners. Accessed July 23, 2026.

“Section 106 is Under Threat,” National Trust for Historic Preservation. Accessed July 23, 2026.