Section 106 has no statutory deadline, causing 3-18 month delays

Any federally funded or permitted construction project near a potential historic site must undergo Section 106 review under the National Historic Preservation Act. While SHPOs have a 30-day response window for individual consultations, the overall process has no statutory deadline and involves multiple sequential steps: identification, evaluation, assessment of effects, and resolution of adverse effects, each potentially involving different stakeholders. For projects near sites that ultimately turn out to have no historic significance, developers still endure the full review timeline. This costs real money: construction delays of 3-18 months mean carrying costs on land, expired permits, missed construction seasons, and in housing-scarce markets, delayed delivery of units people need. The structural cause: the NHPA was written in 1966 when the review volume was tiny, there is no triage mechanism to fast-track clearly insignificant sites, and SHPOs are understaffed to handle the volume of modern development. Congressional attempts to reform Section 106 are opposed by preservation groups who fear any streamlining will gut protections.