AIA Responds to ACHP Vote to Revise Section 106: Calls for Congressional Oversight and Legal Review

WASHINGTON — July 27, 2026 — The American Institute of Architects is opposed to the decision by the Advisory Council on Historic Preservation (ACHP) to move forward with revisions to Section 106 of the National Historic Preservation Act of 1966 for public comment. This hasty proposal represents a significant step back for historic preservation, community participation, and the inclusive design processes that serve the public good.

At its core, the revisions strip communities of their right to be heard. These revisions place approximately 1.4 million historic sites at greater risk by shifting decisions away from the communities where they are rooted. The revisions make public comment optional rather than mandatory, narrow the definition of historic property, and shift decision-making authority almost entirely to federal agencies—sidelining state historic preservation officers, tribal historic preservation officers, tribes, and local governments. They permit agencies to make unilateral determinations through internal reports rather than negotiated agreements, and weaken the requirements to avoid, minimize, or mitigate harm to historic resources. This decision continues a troubling pattern of efforts to weaken longstanding safeguards that ensure communities have a meaningful voice in federal decisions affecting the places where they live, work, and gather.

AIA President Illya Azaroff, FAIA, said, "Public participation is a founding principle of this democracy, and today's vote treats it as an obstacle to be removed. When communities lose their voice in decisions about the places that shape their lives, we all lose something that cannot easily be recovered.

“For architects, Section 106 consultation has always been about listening, learning, and building trust with the people we serve. The current proposal undermines the congressional intent of the National Historic Preservation Act of 1966, and its consequences will be felt across our profession, our neighborhoods, and our communities.”

For architects and the communities they serve, Section 106 consultation enables early integration of preservation considerations, surfaces local knowledge that improves design outcomes, and builds the community trust that meaningful architecture requires. It has never been an obstacle to good design and is one of the country’s most effective tools for preservation planning.

The American Institute of Architects calls on Congress to exercise oversight of the agency and this rulemaking. AIA stands ready to offer architects’ expertise in support of future revisions that respect the intent of the law, preserve meaningful community participation, and strengthen the Section 106 process. The association will continue to work with preservation partners, tribal nations, and policymakers to restore the public participation protections that this vote has placed in jeopardy.