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Archive of Prominent Section 106 Cases:
April 1999

Alabama: Space Simulator
(Huntsville)

Arizona: Holbrook Interchange
(Woodruff Butte)

California: Gold Mine (Imperial County)

Colorado: KMM
Parking Structure
(Black Hawk)

Connecticut: New London Train Station

Washington, DC: World War II Memorial

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Minnesota/
Wisconsin: Stillwater
Lift Bridge

Montana: Military Entrance Processing Station (Butte)

New Mexico:
El Rancho Electric Substation

Ohio: Buffington Island Sand and Gravel Mine

Pennsylvania: Gettysburg National Military Park

Virginia/Maryland: Woodrow Wilson Bridge

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Archive of Prominent Section 106 Cases:
April 1999

Pennsylvania: Visitor Center and Museum Complex, Gettysburg National
Military Park
Members' Formal Report to the Council


A Problem of Common Ground

Introduction

    The influential political philosopher, the late Isaiah Berlin (1909-1997), believed that “all serious political choice involved loss, not merely trade-offs or compromises but genuine sacrifice of desirable ends: so much liberty sacrificed for so much equality or justice sacrificed for the sake of mercy and so on.”1 Whatever the general validity of this theory, we are confronted in Gettysburg with an example of its specific salience.

    The Gettysburg Section 106 consultation will need to be premised on a resolution among three competing historical resources. Such a resolution will depend on a difficult choice that will inevitably sacrifice an otherwise deserving historical resource in furtherance of the treatment of other paramount historical objectives. This sacrifice results from the fact that all the resources in question occupy the same site—common ground literally—a fact that frustrates any effort to seek a metaphorical common ground among the competing values in regard to the basic choice that must be made.

    That basic choice will be dictated by establishing priorities among the competing historic resources, and these priorities will in turn result from weighing, at the highest policy or philosophical level, the historical values represented by each resource. In the context of the Gettysburg issues the assessment of each resource cannot be done in isolation but must be done comparatively, for they exist in relation to each other and not independently.

The Historic Resources Involved

  1. The Gettysburg National Military Park (GNMP) is the site of the Battle of Gettysburg, the Soldiers’ National Cemetery and the commemoration of the battle by its survivors, both of the North and South. The Cemetery is the site of Lincoln’s Gettysburg Address. As a national military park, the GNMP is a cultural landscape automatically listed on the National Register of Historic Places. The GNMP, specifically its cultural landscape, is both the foundation and context for the other two historic resources.
  2. The Cyclorama Painting is the largest of the historic artifacts in the GNMP collection of materials primarily relating to the battle. The painting is huge and was designated as a National Historic object under the Historic Sites Act of 1935 and, in the opinion of the Office of the Solicitor, Department of the Interior, should by virtue of that action be considered as eligible for listing on the National Register of Historic Places.
  3. The Cyclorama Building, designed by the firm of Neutra and Alexander, and opened in 1962 as part of the National Park Service “Mission 66" program intended to accommodate dramatically increased park visitation following World War II. The Keeper of the National Register has determined that the Cyclorama Building is eligible for the National Register of Historic Places because it is “associated with events [the Mission 66 program] that have made a significant contribution to the broad patterns of our history” and is the “work of a master architect,” Richard Neutra.
        This 1998 determination reversed the finding by the National Park Service (NPS) in December 1995, concurred in by the Pennsylvania State Historic Preservation Officer, that the Building was not eligible. The Building is located on the most significant historic landscape at GNMP, just east of the highest point on Cemetery Ridge, a primary defensive position of the Union Army, and was constructed almost 100 years after the battle.

Proposed Undertakings by National Park Service

    As a critical portion of its implementation of its draft General Management Plan/ Environmental Impact Statement (GMP), the park proposes to remove the Cyclorama Building in order to restore the historic landscapes of the Union battle lines of July 2 and 3, 1863, to provide better public understanding of the course of the battle.

    This proposal to create an adverse—indeed, a fatal—effect on a National Register eligible structure is based on the park’s legislative purpose, a statement of significance, historic documentation, and substantial public involvement in the park’s planning processes (see Public Consultation by the GNMP, below). The park also proposes to relocate the Cyclorama Painting to a gallery in a new visitor center in order to provide for its long term preservation and care and to assure its availability for public viewing in an environment that is in compliance with current life safety and accessibility standards.

    The park has also determined that the major design purpose of the Cyclorama Building—the display and preservation of the Cyclorama Painting—can no longer be adequately served by the Building. NPS contends that the Building’s size does not permit the painting to be mounted properly and returned to the painting’s original parabolic shape, does not permit adequate access to the back of the painting for preservation maintenance under current standards, and does not provide adequate insulating space between the painting and the exterior wall of the concrete drum of the structure. These conclusions, however, have been disputed by proponents of the Cyclorama Building.

Public Consultation by the GNMP

    As part of its planning process, the National Park Service (NPS) has consulted extensively with the public, which overwhelmingly supports the philosophy and proposals contained in the GMP. Public involvement has recently shifted to the dispute regarding the fate of the Cyclorama Building. Views of the public and those of organizations and groups, including the Society of Architectural Historians, AIA Pennsylvania, Preservation Pennsylvania, Gettysburg National Military Park Advisory Commission, Friends of the National Parks at Gettysburg, the National Parks and Conservation Association, and the National Trust for Historic Preservation, have been split.

    This difference of opinion was apparent in the consultation meeting among the consulting and interested parties held on April 20, 1999. The Council Member Working Group has reviewed all of the pertinent NPS case materials, public comments and related correspondence, and two Members attended the consultation meeting of April 20 and have attended on-site briefings by NPS staff.

The Basic Choice to be Made

    To many Americans the GNMP is the Civil War. Without question it is the war’s most celebrated and hallowed battlefield. The grand reunion of Civil War veterans, North and South, held at Gettysburg in 1913 on the occasion of the 50th anniversary of the battle, reflected a spirit that makes America’s experience with fratricidal conflict unique in world history. Those who lost the war were not hunted down, prosecuted and executed as traitors; Confederate leaders are represented among statues in the U. S. Capitol. The battlefield’s memorials to both sides thus symbolize the healing of deep wounds and the continuation of the Union.

    This bloody battle of a most bloody war was a seminal event in U. S. history not only for military reasons but for the battlefield’s association with Lincoln’s Gettysburg Address, itself a document in American history that rivals original documents like the Declaration of Independence and the Constitution and is probably much more familiar to the American people. Indeed, many historians regard the Gettysburg Address as signaling a second American Revolution—a correction, as it were, of the American spirit. Few have expressed this more profoundly, and with more scholarly foundation, than Professor Garry Wills:

The Gettysburg Address has become an authoritative expression of the American spirit—as authoritative as the Declaration itself, and perhaps even more influential, since it determines how we read the Constitution itself without overthrowing it.... By accepting the Gettysburg Address, its concept of a single people dedicated to a proposition, we have been changed. Because of it, we live in a different America.2
Gettysburg, as a site, thus represents a post-Independence turning point in national history—our development politically—that has few if any rivals. It is of paramount importance historically. The rehabilitation of this key battlefield site so that the battlefield can properly be interpreted must be regarded as a historic mission of the highest order.

    This imperative transcends the reality that cumulative policies of NPS have compromised this historic landscape in some areas of the battlefield and that any landscape as a natural environment will inevitably change over time. The exact replication of the 1863 battlefield, with its carnage and devastation, and devoid of its commemorative markers, would be impossible and undesirable even if possible.

    The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for the Treatment of Cultural Landscapes recognizes that restoration standards allow for the depiction of a landscape at a particular time in U. S. history by preserving materials from the period of significance and removing materials from other periods. The period of significance selected by the park substantially predates the Cyclorama Building.

    The Cyclorama Building, constructed in 1960 in the southern portion of Ziegler’s Grove, caused substantial changes to the topography and features of this critical portion of the battlefield. It is located just east of the highest point on Cemetery Ridge, the object of repeated Confederate attacks on July 2 and 3 to gain the heights of Cemetery Hill. It was sited at the focal point chosen by the artist of the Cyclorama Painting and provides an observation deck from which can be seen Seminary Ridge, the terrain of the six-mile long Confederate line.

    The siting of the building was based on an approach to visitor orientation that, by today’s standards, would be rejected out of hand; indeed, it is clear that such a location would violate the NPS’s Management Policies, its basic service-wide policy document. These policies provide, among others, that “development will not compete with or dominate park features” (Chapter 9:2); and that “to minimize visual intrusion and harm to major park features, visitor centers will generally not be located near such features” (Chapter 9:11).

    The Advisory Council itself in a June 1977 publication entitled, A Plan to Preserve the Historic Resources of the Gettysburg Area of the Commonwealth of Pennsylvania, called for the relocation of the Cyclorama Building and the nearby visitor center because they were “intrusions near the cemetery and the climactic scene of the battle...” (pp.6-7). No more dramatic demonstration of this intrusiveness can be seen than to move along Confederate Avenue on Seminary Ridge and view the Union’s defensive line from this vantage point. The bulk and scale of the drum of the Cyclorama Building is prominent in the viewshed, and from certain points this and the long office wing with its ramp and observation deck introduce a discordant and disturbing note in an otherwise pastoral landscape dotted with memorials that are themselves testimony to the emotions stirred directly by the events that took place.

    The Council should not reverse its 1977 recommendation in the absence of compelling reasons to do so. The Keeper’s determination of the building’s eligibility (even accepting the premise that the Mission 66 program made a “significant contribution to the broad patterns of our history”) does not rise to this level of persuasiveness because it is focused on the building in isolation from, and not on its relationship to, a paramount historical objective: the rehabilitation of this key battlefield area.

    Those who would question the historic value of such rehabilitation appear to believe that the Building does not diminish or intrude upon visitors’ understanding of the battlefield events or, even if so, future generations may not focus on the military as distinguished from the political significance of Gettysburg, and that the re-creation of the conditions of 1863 is unrealistic in any event. To accept this view would open the door conceptually to further construction in the future that substantially changes the topography and viewshed. Public and scholarly interest with battlefield events has continued unabated for long after the survivors have died. There is no basis to suggest that this would change in the future, and this kind of speculation could undermine historic preservation objectives generally.

    It is no criticism of Neutra to give priority to this rehabilitation objective. The architect was responding to the client’s directive. The massive drum was a direct expression of the function that was to be served by the Building. In other hands the work would doubtless have been done less admirably but just as intrusively because of the massing required to achieve its purpose. With rare exceptions, the millions of people who have visited the GNMP since 1962 have come to see the battlefield and not Neutra’s architecture. Neutra has a secure place in the pantheon of American architectural history. There are other Neutra buildings; there is only one Gettysburg Battlefield. The proper treatment of the Building would be considered under quite different criteria, of course, were it on some other site without superior historical competition.

    The continued existence of the Building is consequently pre-empted by another controlling historic preservation objective. In such circumstances it is not necessary to enter upon any examination of whether the building can be adapted to another use or can feasibly be altered to accommodate the Cyclorama Painting or whether the Painting can be accommodated without any such alteration. To engage in this examination is to presuppose that the Building can trump the objective of battlefield restoration and rehabilitation. It is also not necessary to evaluate, accept, or reject the asserted defects of the Building in either design, construction or maintenance. For the purpose of the unpleasant choice posed by its unfortunate siting, it should be assumed that the building is completely functional in all these respects. The result is the same. The Building must yield.

Conclusion

    Accordingly, it is our recommendation that the Council endorse the GNMP General Management Plan in regard to the treatment of the three historic resources in question. It is not necessary, in our view, for the Council at this time to concern itself with the controversy regarding certain aspects of the new proposed Visitor Center other than to endorse the plan to house within it the Cyclorama Painting under conditions suitable for its proper preservation and display. This should be the focus of future Section106 consultations, along with other mitigation policies as suggested by the National Trust for Historic Preservation, to include review of the landscape restoration plans.


Submitted by:

Council Member Working Group

        Herbert M. Franklin
        Bruce D. Judd
        Parker Westbrook

Date: May 10, 1999


ENDNOTES

1Ignatieff, Michael. 1998. Isaiah Berlin, A Life (p. 228). H. Holt and Co.
2Wills, Garry. 1992. Lincoln at Gettysburg: The Words that Remade America (p. 147). New York.


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