The undersigned associations (the “Coalition”) offer the following comments in response to the U.S. Army Corps of Engineers’ (“Corps”) proposed rule concerning procedures for the protection of historic properties under Section 106 of the National Historic Preservation Act (“NHPA”), as those procedures relate to the processing of Department of the Army permits by the Corps’ Regulatory Program.1 As explained below, the Corps should not revoke its agency specific procedures (“Appendix C”)2 for complying with the NHPA or rely exclusively on regulations issued by the Advisory Council on Historic Preservation (“ACHP”), to be supplemented by forthcoming guidance that has not been made available for public review. The Appendix C procedures specify how the Corps demonstrates compliance with Section 106 of the NHPA. This includes the critical Nationwide Permit (“NWP”) Program, a streamlined program intended to authorize minor activities with minimal review time. Rather than abandoning its longstanding agency-specific process, which is contemplated by the NHPA, to the extent needed the Corps could propose targeted amendments to Appendix C through a notice and comment rulemaking.