Coalition Recommends Repeal or Replacement of Appendix C

The Coalition for American Heritage recognizes that Appendix C procedures are hindering historic preservation efforts. In a letter to the United States Army Corps of Engineers (USACE), the Coalition suggests that the USACE revise or replace Appendix C of 33 CFR part 325.

We wrote the letter in response to a call for comments from the USACE.  The USACE, like other federal agencies, is trying to implement President Trump’s Executive Order on “Enforcing the Regulatory Reform Agenda,” requiring agencies to reduce the number of regulations.

In our letter, we note that Appendix C procedures were never approved as a counterpart regulation by the Advisory Council on Historic Preservation. The procedures have been problematic in several ways and have left the USACE vulnerable to litigation. Furthermore, the Appendix C procedures have been applied inconsistently across the country and have limited the USACE’s ability to be a good steward of America’s historic and prehistoric heritage.

To read our letter to the U.S. Army Corps of Engineers, click here.

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