San Francisco, CA 94129
Dear Mr. Middleton:
The National Park Service (NPS) is pleased to provide the Presidio Trust (“Trust”) with consolidated comments on all of the documents released to date regarding the Presidio Trust Management Plan Main Post Update. The comments here enclosed encompass our review of:
revised Finding of Effect (FOE) for the Main Post Update
These comments supplement NPS’s previous letters1 and the 213 Report NPS prepared for the Advisory Council on Historic Preservation (ACHP). All of these comments, letters and the 213 Report are to be taken collectively as our input on the process.
Together, the Supplement to the DSEIS, the Revised FOE and the Main Post Update present both the Trust’s preferred alternative under NEPA and its undertaking for the purposes of the NHPA. For ease of reference, we will simply refer to both the NEPA preferred alternative and the NHPA undertaking as the “Project”. The NPS commends the Trust’s efforts to reduce the impact of the Project and the many changes made since the initial consultation documents were released in June 2008. Unfortunately, these revisions have not relieved NPS’s concerns that the Project and the accompanying documents fall short of fully addressing the potential impact of the Project on the Presidio, and in particular, on the Main Post, the historic core of the Presidio.
We hope the Trust will proceed to refine a preferred alternative that truly preserves and protects the Presidio’s National Historic Landmark status through rehabilitation and preservation of historic buildings and associated landscape features of the Main Post
consistent with the Secretary of the Interior’s Standards for the Treatment of Historic Properties. The NPS supports an alternative that would maximize the rehabilitation of historic structures, avoid and minimize adverse effects on the NHLD, minimize the amount of new construction, minimize the removal of existing buildings (especially contributing resources), preserve and protect the Main Post’s significant resources (including natural resources), and demonstrate the highest level of sustainable practices with the least amount of adverse environmental impacts, and reflect the Trust’s stewardship responsibilities. As currently constructed, the preferred alternative has a cumulative adverse effect on the NHLD, however, if specific elements of the preferred alternative were dropped (such as the removal of contributing buildings) and others altered to minimize the adverse effect, it is possible a viable preferred alternative could be presented that meets the general goals of the Presidio Trust.
Our concerns fall into four broad categories. We touch on each in this letter, and then expand upon them in more depth, and describe various other concerns in the next section of these comments. The final section of this document consists of individual, specific comments on specific points made in each of the Trust’s documents.
The four primary concerns that we discuss in this cover letter are:
The Project appears to conflict with the Trust’s stewardship mandates under the Presidio Trust Act and other legislation;
The Project appears to involve far more construction than is authorized in the Presidio Trust Act;
The Project appears to risk the Presidio’s current designation as a National Historic Landmark District; and
The Project’s apparent conflict with the Presidio Trust Management Plan.
NPS is concerned that the Project is inconsistent with the Trust’s stewardship mandates as expressed in the Presidio Trust Act. The Presidio Trust Act requires the leasing, rehabilitation and improvement of properties within the Presidio to be exercised in accordance with the purposes for which the Golden Gate National Recreation Area (GGNRA) was established. (Trust Act Section 104(a).) The GGNRA’s purposes are echoed in the Trust Act, which states that, “as part of the Golden Gate National Recreation Area, the Presidio’s significant natural, historic, scenic, cultural and recreational resources must be managed in a manner which is consistent with sound principles of land use planning and management, and which protects the Presidio from development and uses which would destroy the scenic beauty and historic and natural character of the area and cultural and recreational resources.” (Presidio Trust Act, Section 101 (5)). The Trust Act further directs the Trust to manage the Presidio in accordance with the “general objectives” of the 1994 General Management Plan Amendment (GMPA). (Trust Act Section 104(a).) As many of our specific comments also point out, we are concerned that elements of the Project will not enable the Trust to fulfill these legislative mandates.
NPS’s second concern is that the Project proposes large scale changes to the Main Post, including significant new construction, which appear to conflict with the Trust Act’s legislative mandates. The Trust Act states that new construction must be “limited to replacement of existing structures of similar size in existing areas of development.” (Trust Act Section 104(c)(3).) As with other portions of the Act, this proviso should guide the Trust in its stewardship of the Presidio. The large increase in new construction, far in excess of that authorized in the PTMP, appears to conflict with this provision and requirement of the Trust Act.
As a stewardship agency charged with preserving and protecting the Presidio’s superlative resources, including its status as a National Historic Landmark District (NHLD), we encourage the Trust to reevaluate the Project in light of these mandates.
As a federal agency, and in accordance with 36 CFR Section 800.10(a), the Trust is required “…to the maximum extent possible, undertake such planning and actions as may be necessary to minimize harm to any NHL that may be directly and adversely affected by an undertaking.” NPS continues to have serious concerns about the amount of change proposed at the Main Post, namely through demolition and new construction, and the subsequent level of effect that the Project will have on the historic integrity of the Main Post. Our Section 213 Report concluded that the proposed undertaking would have a significant adverse effect on the Presidio NHLD, and we therefore proposed a suite of recommendations that could help avoid or minimize this effect. We hope that the Trust will seriously consider those previously transmitted recommendations.
Additionally, omissions, inconsistencies, and unanalyzed impacts in the environmental documents place the preferred alternative at odds with the Presidio Trust Management Plan’s (PTMP) planning principles. We are concerned with the effect of the Main Post Update on the PTMP. The PTMP was based on the 1994 GMPA for the entire Presidio. The PTMP was needed to account for and reflect Trust Act requirements, changed circumstances, and new policies and management approaches while adhering to the general objectives of the GGNRA’s General Management Plan.. The NPS worked with and supported the Trust through that planning effort and the resulting land use document for Area B of the Presidio. However, we believe that the proposed changes to the Main Post so exceeds the parameters of what was considered and approved in the PTMP that either the preferred alternative for the Main Post Update needs to be revised to align with the PTMP, or the Trust needs to expand the Project boundaries to include those other planning areas that would be affected by actions under consideration at the Main Post.
Finally, the Presidio Trust Act states that the Secretary of the Interior shall retain jurisdiction over Building 102 for use as a Visitor Center, to be named the “William Penn Mott Visitor Center” and that the NPS, in cooperation with the Trust, is responsible for “providing public interpretive services, visitor orientation, and educational programs” in the Presidio. We hope to cooperate with the Trust in this, and in all other aspects of the Project. We believe that with additional refinement, the Trust can develop a proposal that will provide an exceptional visitor experience worthy of this great national park in balance with its long-term preservation and enhancement.
We commend the recent efforts of the Presidio Trust in listening to and acknowledging the array of concerns shared by environmental and preservation organizations, neighbors, as well as consulting parties to the Section 106 process. We encourage the Trust to continue with this collaborative process, and we look forward to ongoing dialogue with the Trust as this process moves forward.
/s/ Frank Dean
Acting General Superintendent
1 The NPS has provided previous comments on the Main Post Update in letters dated December 21, 2007 (scoping comments), April 4, 2008 (Section 106 assessment of effect comments), and December 18, 2008.