https://armypubs.army.mil/epubs/DR_pubs/DR_a/ARN30648-ARMY_DIR_2020-10-000-WEB-1.pdf
S E C R E T A R Y O F T H E A R M Y
W A S H I N G T O N
MEMORANDUM FOR SEE DISTRIBUTION
SUBJECT: Army Directive 2020-10 (Use of Imitative Substitute Building Materials in
Historic Housing)
1. References.
a. National Historic Preservation Act (NHPA); Public Law 13-287; Title 54,
U.S. Code, section 300101 et seq.
b. Title 36, Code of Federal Regulations, Part 800 Protection of Historic
Properties (36 CFR 800)
c. Senate Armed Services Committee Report, Senate Bill 4049, Fiscal Year 2021
National Defense Authorization Act, Title XXVIII (Military construction and general
provisions), Subtitle E (Improvements to the management of historic homes)
d. Army Regulation (AR) 200–1 (Environmental Protection and Enhancement)
2. Purpose. This directive establishes policy for the use of imitative substitute building
materials in Army-owned and privatized historic housing, and for the inclusion of such
materials in NHPA Section 106 memorandums of agreement (MOAs) and programmatic
agreements (PAs).
3. Background. The Army manages the largest inventory of historic housing in the
Federal government. Historic housing is housing that is subject to NHPA statutory
requirements and NHPA Section 106 compliance procedures in 36 CFR 800.
Management of this large inventory of historic housing requires the Army to balance
historic preservation considerations required under the NHPA with quality-of-life issues;
health risks associated with lead-based paint, asbestos, and other hazards found in
historic building materials; and the high costs of historic building materials and in-kind
building materials. The judicious use of imitative substitute building materials in lieu of
historic building materials and in-kind building materials for the maintenance, repair,
rehabilitation, and renovation of historic housing helps to achieve that balance. Imitative
substitute materials are cost-effective, last a reasonable length of time, provide an
accurate simulation of historic building materials and, with proper planning and
selection, will successfully maintain the historic and architectural characteristics of
historic housing.
SUBJECT: Army Directive 2020-10 (Use of Imitative Substitute Building Materials in
Historic Housing)
2
4. Applicability. This directive applies to the Regular Army, the Army National
Guard/Army National Guard of the United States, and U.S. Army Reserve. Contracts to
operate Government-owned facilities will reference this directive and will designate by
specific citation the applicable provisions.
5. Policy.
a. Imitative substitute building materials are modern, industry standard, natural,
composite, and synthetic materials that simulate the appearance of and substitute for
more costly historic building materials and in-kind building materials. Historic building
materials are building materials that are 50 years old and older. In-kind building
materials are new building materials that are identical to historic building materials in all
possible respects, including their composition, design, color, texture, and other physical
and visual properties.
b. Imitative substitute building materials will be considered for use in the
maintenance, repair, rehabilitation, and renovation of Army-owned and privatized
historic housing when the quality of life, health, and safety of housing occupants is of
concern, or when the use of historic building materials and in-kind building materials is
not financially feasible.
c. Imitative substitute building materials will be selected and used with appropriate
planning to ensure that the historic and architectural characteristics of historic housing
are maintained.
d. All NHPA Section 106 MOAs and PAs pertaining to historic housing that are
amended or executed after the date of this directive shall provide for the use of imitative
substitute building materials in Army-owned and privatized historic housing to the
maximum extent possible.
e. Any privatized housing partner holding title to historic Army housing shall be an
invited signatory to all NHPA Section 106 MOAs and PAs pertaining to that housing that
are amended or executed after the date of this directive.
f. This policy applies to Army-owned and privatized historic housing subject to the
requirements of the NHPA. This policy does not apply to historic housing addressed in
NHPA Section 106 Program Comments issued pursuant to 36 CFR 800.14(e), historic
housing that has been formally designated by the National Park Service as a National
Historic Landmark, and historic housing that has been formally designated by the
National Park Service as a contributing property within a National Historic Landmark
SUBJECT: Army Directive 2020-10 (Use of Imitative Substitute Building Materials in
Historic Housing)
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District. This policy does not apply to Civil Works functions of the U.S. Army Corps of
Engineers.
6. Proponent. The Deputy Chief of Staff, G-9 is the proponent for this directive and,
under the policy oversight of the Assistant Secretary of the Army for Installations,
Energy and Environment, will incorporate its provisions into AR 200–1 within 2 years.
7. Duration. This directive is rescinded on publication of the revised regulation.
Ryan D. McCarthy
DISTRIBUTION:
Principal Officials of Headquarters, Department of the Army
Commander
U.S. Army Forces Command
U.S. Army Training and Doctrine Command
U.S. Army Materiel Command
U.S. Army Futures Command
U.S. Army Pacific
U.S. Army Europe
U.S. Army Central
U.S. Army North
U.S. Army South
U.S. Army Africa/Southern European Task Force
U.S. Army Special Operations Command
Military Surface Deployment and Distribution Command
U.S. Army Space and Missile Defense Command/Army Strategic Command
U.S. Army Cyber Command
U.S. Army Medical Command
U.S. Army Intelligence and Security Command
U.S. Army Criminal Investigation Command
U.S. Army Corps of Engineers
U.S. Army Military District of Washington
U.S. Army Test and Evaluation Command
U.S. Army Human Resources Command
Superintendent, U.S. Military Academy
Director, U.S. Army Acquisition Support Center
(CONT)
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SUBJECT: Army Directive 2020-10 (Use of Imitative Substitute Building Materials in
Historic Housing)
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DISTRIBUTION: (CONT)
Superintendent, Arlington National Cemetery
Commandant, U.S. Army War College
Director, U.S. Army Civilian Human Resources Agency
CF:
Director of Business Transformation
Commander, Eighth Army
