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									John L. Nau. III

Bernadette Castro
Vice Chairman

Emily Summers, ASID
Dallas, TX

Mark A. Sadd
Charleston, WV                                                   Preserving America's Heritage
Susan S. Barnes

John G. Williams,         III, AlA
Seattle, WA

Julia A. King, Ph.D.
St. Mary's City, MD

Ann A. Pritzlaff                     August22, 2005
Denver, CO

Gerald P. Jemison                    The Honorable Gordon R. England
Victor, NY
                                     Secretary of the Navy
Governor Timothy                     1000 Navy Pentagon
St. Paul, MN                         Washington, DC 20350-1000
Vacant                               Dear Mr. Secretary:
Alan M. Hantman,    FAIA
Architect of the Capitol             I am writing to convey to you the comments of the Advisory Council on Historic Preservation
Hon. Mike Johanns                    (ACHP) to help resolve a dispute regarding plans by the U. S. Department of the Navy to
Secretary of Agriculture
                                     demolish historic structures at Naval Air Station (NAS) Pensacola, Florida. The proposed
Hon. Gale A. Norton                  actions are part of an overall program by the Navy to recover from damages caused by
Secretary of the Interior
                                     Hurricane Ivan. These comments are offered in accordance with Stipulation Ill.E.2.c. of the
Hon. Stephen L. Johnson              Memorandum of Agreement (MOA) entered into on March 11,2005, by the Navy, the
Environmental                        ACHP, and the Florida State Historic Preservation Officer (SHPO) to meet the Navy's
Protection Agency
                                     responsibility under Section 106 of the National Historic Preservation Act.
Hon. Stephen A. Perry
Administrator, General
Services Administration
Hon. Donald H.                       On September    15,2004, HurricaneIvan struckthe panhandle      areaof Florida, ca~sing
Rumsfeld                                                to                 and
                                     extensivedamage NAS Pensacola environs.Sustaining               particular damage  wasthe
Secretary of Defense
                                     Pensacola   NAS Historic District, a National Historic Landmark(NHL). This 82-acredistrict
Hon. Norman         Y. Mineta
Secretary of
                                     containsthe remainsof the 19th-century   Pensacola  Navy Yard and the later-established  NAS,
Transportation                       the fifst suchpermanent  facility andthe first Navy pilot training centerin the United States.
Jonathan Kemper                                   to
                                     Responding the widespread       damage,  Congress  enactedon October13,2004,the Military
for Historic
                 National    Trust
                                     Construction  Appropriationsand Emergency      Hurricane Supplemental   AppropriationsAct,
                                     2005, which provided specialrecoveryfundsto NAS Pensacola, directedthe Navy to
Jay D. Vogt
President,  National                 obligatethesefunds by September 2005.30,
Conference    of State
Historic Preservation
Officers                                                    and
                                     As cleanupoperations damage        assessments beganin the wake of the storm,the Navy
                                     notified the Florida SHPO,the National Park Service(NPS), andthe ACHP on October6,
                                     2004, that it intendedto proceedunderthe emergency    provisionsin the ACHP's regulations
John M. Fowler
Executive Director                   on its plansto repairand demolishhistoric propertieson the base.Consultation,in which the
                                     National Trust for Historic Preservation(NTHP) andthe NPS alsoparticipated,was very
                                     difficult dueto the extentof demolitionproposed time pressures.        Agreement    was finally
                                     reachedthat accepted   much of the proposeddemolition of historic structures, 16but
                                     structuresof "greatestsignificance"to the historic district were identified as needingfurther

                                                      ADVISORY COUNCIL ON HISTORIC PRESERVATION
                                               1100 Pennsylvania Avenue NW, Suite 809 .Washington,   DC 20004
                                           Phone: 202-606-8503 .Fax: 202-606-8647

The MOA called for the Navy to preparefor eachbuilding a preservation   analysisreport (PAR) to
examinehistoric and architectural value,assess         and
                                              damage, estimatecostsassociated       with various
treatmentoptions.The consultingpartiescould commenton eachPAR, with the Navy thendeciding how
eachof the 16 buildings would betreated.Following notification of the Navy's decision,the consulting
partiescould object,thus triggering disputeresolutionprovisions in the MOA that provide for further
ACHP review and comment.

By June 18,2005,the 16 PARswere providedto the consultingparties.The Florida SHPOand NTHP
providedextensivecommentson the reportsand, on July 15,the Navy notified the consultingpartiesof
its intentionto proceedwith demolition of all but threebuildings. Anticipating likely objectionfrom the
consultingparties,the Navy notified the ACHP that it was invoking the disputeresolutionprovisions in
the MOA.

         to                                                                           to
Pursuant the terms of the MOA, I electedto providethe Navy with ACHP commentspursuant 36
CFR Section800.7(c),andto expediteour review I appointed panelof ACHP members.The panel,
which I chaired,consisted expertmemberSusan    Barnes;expertmemberJohnG. Williams; Mark Rey,
                                   and                          the          of
Under Secretaryfor Natural Resources Environment,representing Secretary Agriculture; and
GeorgeSchoener,                           for
                 Deputy AssistantSecretary Transportation                     the
                                                          Policy, representing Secretaryof

On August 8, 2005,the panelvisited NAS Pensacola the Navy provided it with a tour of the NHL
district. That afternoon,we conducted public meetingand receivedtestimonyfrom concerned  State
officials, private organizations, individuals.The comments                     that
                                                           and recommendations follow are
basedon consideration the ACHP of the facts in the caseandthe review and deliberationsof this

Consultation under Section106 hasled to agreementwith most ofthe Navy's proposedrecovery
program, to include plans to repair and rehabilitate manyproperties within the installation's numerous
historic districts and the demolition of manyhistoric propertieslisted in or determinedeligiblefor
listing in the National Register ofHistoric Places.All consultingpartiesin the Section106process,in
particular the Florida SHPO,recognized enormoustaskfacedby the Navy in recoveringfrom damage
causedby HurricaneIvan. In this spirit, and in recognitionof the uniqueand unprecedented
circumstances                                                             the
                confrontingthe installation,the consultingpartiesaccepted Navy's plansto demolish
27 damaged                       many within the NHL district. This acceptance
              historic structures,                                             facilitated the Navy's
overall recoveryplans,but as more andmore historic propertieswere slatedfor removal,therewas a
growing sense urgencyoverthe fate of the remainingbuildings of greatest      significanceto the NHL
district. Debateoverthe future of thesebuildings shouldnot diminishthe fact that the Navy hasachieved
in largemeasure    agreement  under Section106 regardingits recoveryprogram.Nor shouldthe Navy be
surprisedthat preservation   concernsfor theseremaining16buildingsare so acute.

The NAS PensacolaHiS'toricDistrict is' an hiS'toric property of importanceto the Navyand the Nation
as a whole. As one of the United States'earliestNavy yardsandthe birthplaceof naval aviationasthe
United States'first permanent naval air stationand flfst Navy pilot training center,NAS Pensacola
occupiesan importantrole in American history and a seminalrole in Americannaval history. The district
was listed in the National Registerof Historic Placesin 1976at a nationallevel of significance.That same
year it receivedthe highestrecognitionan historic propertycan achieve;it was designated National
Historic Landmark.Collectively, the 16buildings of greatest   significancethat arethe subjectof this
dispute,to include industrialand supportservicestructures officers' quarters,     provide visual evidence
of the evolving periodsof significanceof the district, from navalyard to NAS. The contributing
propertiesof the NHL district offer testimonyto the rich heritageof the Navy and,as such,canserveasa

sourceof inspirationand instructionfor military and civilian personnel their families as part ofNAS
Pensacola'simportanttraining mission. But while thesebuildings hold a specialvalue for the Navy, it
                     that               the
shouldbe emphasized in a real sense Navy holds this NationalHistoric LandmarkDistrict in trust
for the Americanpublic, an obligationthat carrieswith it a specialstewardship

The Navy's current demolitionplan will have seriousconsequences the historic district and its
NHL designation.On July 21, 2005 RearAdmiral C. E. Weaver,Director, AshoreReadiness            Division,
            the                   to
announced Navy's response the PARs andcommentsfrom the consultingparties.Of the 16
buildings, the Navy had decidedto repair Building 26 to supportthe port operations   functions, Building
28 for storage,and Quarters7 (andan adjacentsupportstructure)for ceremonial       functions.The Navy also
proposedto retainthe smokestack Building 47 and createa landscape          plaza.The remaining 13
buildings of greatest  significanceto the NHL district would all be demolished.In testimonyfrom the NPS
it was confirmed thatthe removalof thesecritical core structures                 the
                                                                   that document district's period of
significancewould have suchdire consequences the district that withdrawal of the NHL listing by the
          of                                                                      a
Secretary the Interior would be highly probable.The Florida SHPOexpressed similar opinion. The
likelihood that its proposed  demolitionscould leadto the removalof the NHL designation NASfor
Pensacola                               to
           shouldbe of greatconcern the Navy.

The Navy's analysisdemonstrates      that optionsto demolitionexist. The PARs developedby the Navy's
consultants  were exceptional,providing anobjectiveand professional                  of
                                                                       assessment eachbuilding's
historic merit, structuralcondition,and associated   treatmentoptions.Basedon a thoroughstructural
analysis,the reportauthorsconcludedthat all 16buildingswere structurallysoundandrepairable.They
also providedan exhaustiveanalysisof treatment      optionsand their costs.It is surprisingthatthe Navy did
not rely more on the findings in thesereports.Indeed,therewas little, if any, reference the reportsby
the Navy in justifying its decisionto retain only threeof the buildings. It is further puzzlingwhy, during
the onsite inspection                                  at
                      and aspart of the presentation the public meeting,the Navy madevirtually no
reference the reportsand their conclusions.    The ACHP panelfound it highly relevantto its
deliberationsthatthe reportsconcludedthatthe buildings are structurallysoundand in repairable
                                       for                     the
condition, and that the costestimates demolitionexceeded mothballingestimatesfor eachof the
16 buildings.

Public opinion standsin strong oppositionto the Navy'splans. If the public meetingconducted the
ACHP is a fair indication,thereexistsconsiderable  public concernoverthe Navy's demolitionplans.
Testimonyfrom Stateof Florida officials, local organizations, individuals all expressed strong
oppositionto the proposed  demolition.No one spokein favor of the Navy's demolitionplans,nor
expressed supportfor the proposed  landscaped plaza.Testimonyfrom former Naval officers, former
occupants the Admiral's Row, and Pensacola      residentsexpressedconcernthat by carrying outthe
demolition of the NHL, the Navy would cause long-termrift in the Pensacola  community.Local media
coverageleadingup to and following the public meetingandthe editorial positionof the Pensacola News
                                       of                   the
Journalall conveyedsimilar sentiments concernregarding Navy's plans.

The demolitionplans are at oddswith Federal stewardship    goals and the standardsthe Navyhas set/or
itself From availableevidence, includethe initial Figure of Merit scoringthat was usedby the Navy
               to                                     1,
and presented the consultingpartiesat the December 2004meetingin Atlanta, we haveconcluded
that the Navy setinto motion plans for extensivedemolitionof historic propertieswithout consideringthe
unique historic value of theseproperties. Oncecommittedto this courseof action,the Navy became
unwilling to rethink its earlierflawed planningassumptions. find this actionto be contraryto the
Navy's responsibilitiesunder Section110(f) of the NationalHistoric Preservation Act, which directs
                  to            to
Federalagencies undertake the maximumextentpossible,planningand actionsto minimize harmto
a National Historic Landmark,and the stewardship  goals of ExecutiveOrder 13287,"PreserveAmerica."
In that order, President                             to
                         BushdirectedFederalagencies recognizeand managehistoric propertiesin

their ownership''as assets                         and
                          that can supportdepartment agencymissionswhile contributingto the
vitality and economicwell-being of theNation'scommunities                                  for
                                                         and fosteringa broaderappreciation the
              of                 and
development the United States its underlyingvalues."

The Navy, under its own policy and instructions (SECNA VINST 4000.35A and OPNA VINST 5090.1B
CH-23) states that protection of its historic properties is "an essential part of the defense mission... [for
which the Navy] is committed to responsible cultural resources stewardship." It is instructive that NAS
Pensacola claims in its own Command Vision for the 2151       century to be recognized as an "[a ]cknowledged
leader in preserving its natural beauty, tradition, and rich history, enhancing our reputation as the most
aesthetically pleasing installation in the Navy." It would be difficult to reconcile this claim with carrying
out a demolition program that led to the withdrawal of the National Historic Landmark.

The ACHP is fully awareof the difficult positionthe Navy is in with the needto obligate by the end of
                                                  for                            As
FY 2005 the specialfunding providedby Congress recoveryat NAS Pensacola. this datedraws
near,the Navy may believe that its bestcourseof actionis to move forward with its demolitionplans.We
believe that sucha courseof actioncould invite challenges would not be in the bestinterestof the
Navy and its overall recoveryprogram.Accordingly, and in an attemptto helpresolvethe disputewe
                           the                     that
have beenaskedto address, ACHP recommends the Navy take immediatestepsto re-evaluate                its
plansand limit demolitionto the maximumextentpossible,basedon the following considerations:

        The proposalto repair Buildings 26 and28 and Quarters7 shouldproceed.

        Because reuseoptions for Building 47 are extremelylimited by its prior useand stormdamage,
                                                       We                            to
        the demolition of this structurecanbe accepted. favor the Navy's proposal retainthe
        smokestack, we recommend                             of                               that
                                         further consideration the Florida SHPO's suggestion the
        north and southwalls be retainedto provide a visual and interpretivecontextfor the smokestack.

        Due to the previouslyapproveddemolitionof Buildings 604 and 52, Buildings 18 and 45 will be
        effectively isolatedfrom the core of the NHL district. Accordingly, and because missionneeds
        and conditionsassessments,  Buildings 18 and45 demolitioncould proceed.

        Becauseof extensivedamageto its roof, subsequent   weather damageand becauseit does not
        conveywith the samesenseof clarity and importanceits aviationrole as a hangar,in contrastto
                                 Hangars73 and 74, Building 27 canbe demolished.
        its neighboringstructures,

        All other buildings involved in this dispute--Buildings1, 74, and 223 and Quarters2, 3, 4, 5, 6,
        and 8--should be retained and steps taken to further clear them of debris, secureand stabilize
        them, and provide protection from the elements.Longer term, the Navy should examinefuture
        sensitiveadaptiveusesfor thesebuildings in conjunctionwith conversionof the NHL district to
        Mission-Supportor Quality of Life statusso that suchusescould be encouraged.   Collectively, all
        these remainingbuildings are essentialin providing visual evidenceof the evolving periods of
        significanceof the district, from navalyard to NAS.

In accordancewith Section106of the NationalHistoric Preservation   Act, you musttake into account
thesecommentsof the ACHP prior to reachinga final decisionon the Navy's plans for the 16 buildings
          significanceto the NHL historic district. In accordance
of greatest                                                                       of
                                                                with Section110(1) the actandthe

                                   this responsibilitycannotbe delegated.
 Section106 implementingregulations,                                                          to
                                                                         Finally, your response
the ACHP commentsmustbe documented accordance         with 36 CFR Section800.7(c)(4).


JohnL. Nau, III

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