New Battle at the Little Bighorn Jun 8, 2008 10:02:02 GMT -5
Post by Diane Merkel on Jun 8, 2008 10:02:02 GMT -5
Thanks to Lee Noyes for the following:
NEW BATTLE AT THE LITTLE BIGHORN
Planned “Temporary” Visitor Center in Center of Battlefield Draws Historians’ Ire
Washington, DC — A plan to build an expanded visitor center at the Little Bighorn Battlefield National Monument in Montana has sparked heated opposition from historians, two former park superintendents and conservation groups. This week, Public Employees for Environmental Responsibility (PEER) and the Coalition of National Park Service Retirees (CNPSR) have asked NPS Director Mary Bomar to halt the plan and review its appropriateness, legality and impact on the historic battlefield.
Under the plan, an enclosed theater seating 200 people would be built at the base of Last Stand Hill, site of the climax of the 1876 battle in which General George Armstrong Custer and five companies of the 7th Cavalry were wiped out. On April 23, 2008, the National Park Service cleared the project for construction, slated to begin as early as this summer.
Although the site is now occupied in part by a patio attached to the current visitor center, the expansion has drawn heavyweight opposition, led by former NPS Chief Historian Robert Utley, because it would –
- Occupy the heart of the battlefield and intrude on the historic landscape;
- Contradict the 1986 General Management Plan (GMP) for the park which envisions a new visitor center near where the battle started and out of the battle sightlines; and
- Violate the philosophy of historic preservation embodied by the much-praised new visitor center at Gettysburg, which does not visually intrude on the cultural landscape.
“While the NPS contends that this building would only be a stopgap measure, inadequate temporary structures have a tendency to be left in place for decades,” said Bill Wade, Executive Council Chair of the CNPSR, noting that a private group led by a former Little Bighorn Battlefield National Monument superintendent has already purchased lands and raised funds for the new visitor center envisioned by the GMP. “This plan makes the current situation much worse and gets in the way of what should be done.”
As recently as last year, the National Park Service itself conceded that the project would have an “adverse impact” on the battlefield but reversed that finding without explanation. In addition, according to a legal analysis by PEER, the plan appears to be at odds with the National Environmental Policy Act, the National Historic Preservation Act and the Service’s own Management Policies.
“The latest Park Service finding that this project would have ‘no significant impact’ does not stand up to scrutiny,” stated PEER Senior Counsel Paula Dinerstein, pointing to NPS policies that are supposed to prevent the agency from putting itself between visitors and the park resource. “A theater to display an NPS-produced film should not be in the middle of the very battlefield it is supposed to preserve.”
The PEER letter also asks Director Bomar to suspend the project in order to avoid litigation.
May 16, 2008
Mary A. Bomar
Director, National Park Service
1849 C Street, N.W.
Washington DC 20240
Dear Director Bomar:
Public Employees for Environmental Responsibility (PEER) has taken note of the growing controversy over the proposed expansion of the visitor center at the Little Bighorn Battlefield National Monument, Montana. The visitor center was built in 1952 and, like the large visitor center and cyclorama at Gettysburg, reflected the philosophy of then-Director Conrad Wirth that visitor centers should be placed as close to the resource as possible–in that instance the Bloody Angle where Pickett’s charge climaxed. At Little Bighorn, the visitor center is at the very base of Last Stand Hill and in the heart of the battlefield.
Since enactment of the National Historic Preservation Act of 1966, the nation’s philosophy of historic preservation has radically shifted. The National Park Service adapted to the new philosophy and moved away from the central concepts of the Wirth era. At Gettysburg the old visitor center and cyclorama have been demolished and a new visitor center placed out of sight but still not far from the Bloody Angle.
At Little Bighorn, the visitor center has for years been considered an unacceptable intrusion on the cultural landscape. This is reflected by the General Management Plan (GMP) of 1986, revised in 1995, calling for a new visitor center that does not visually intrude on the cultural landscape. Now, the National Park Service proposes to enlarge the old visitor center to accommodate immediate needs. This striking contrast in management decisions directly violates one of your underlying principles in the 2006 Management Policies–"one national park system."
The proposed development also violates the underlying principle of ensuring that conservation will be predominant when there is a conflict between the protection of resources and their use. The expanded visitor center would aggravate the intrusion on the historic resource recognized in the GMP in order to accommodate visitor use. Investment in such an undertaking is, of course, also likely to postpone the realization of the GMP for the indefinite future.
Yet, an "interim" FONSI (Finding of No Significant Impact)–interim to imply ultimate accomplishment of the GMP– was approved on April 21, 2008 by Intermountain Regional Director Michael Snyder, thus freeing construction to proceed.
PEER has conducted an analysis of this FONSI and finds it deeply flawed and entirely inadequate to support a determination of no significant impact. The instances in which it reflects a failure to apply fundamental policies of the NPS Management Policies, NPS-28, the Advisory Council on Historic Preservation’s procedural regulations and criteria of adverse effect, and even the 1916 Organic Act are too numerous to burden this letter.
Some of the most serious flaws appear obvious enough in themselves to invalidate the FONSI. For example, the proposed enlargement is described in only a few confused sentences that defy the understanding of even those familiar with the building, a flaw compounded by the absence of any drawings to illustrate the changes. Another flaw is the failure to follow procedures for public consultation and dispute resolution set forth in the regulations implementing section 106 of the National Historic Preservation Act. NPS appears never to have identified and initiated consultation with anyone but the State and later Tribal Historic Preservation Officer, although it surely was aware that there were and are many parties who would be concerned about such a major change in treatment of the Battlefield. The State and Tribal Historic Preservation Officers were simply presented the preferred alternative and asked for concurrence. Finally, the objective of the GMP to remove the visitor center altogether from the cultural landscape is obviated by the determination of no significant impact of the enlarged structure on the cultural landscape. More particulars of our analysis can be provided upon request.
We believe that proceeding with the project based on this FONSI would be vulnerable to legal challenge under the National Environmental Policy Act, the National Historic Preservation Act and other legal authorities. Equally important, the project is simply inconsistent with basic management principles of the National Park Service. We strongly urge you to suspend construction in order to consider the issues we raise, and to obtain an analysis of the FONSI by a cultural resource specialist on your own staff, who can provide you with an assessment of its adequacy to justify the project.
Please let us know by May 30, 2008 whether you agree to suspend further action on this project pending your further review. If the project is not suspended by that date, PEER will consider other options to achieve that end. We appreciate your attention to this matter.
PEER Senior Counsel
Cc: John M. Fowler, Executive Director, Advisory Council on Historic Preservation
To see the letter from the ACHP go to: www.peer.org/docs/nps/08_19_5_achp_lbh_ltr.pdf