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The Campaign to Save Richard Neutra's
Cyclorama Building at Gettysburg

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Section 106 Case Report, Cyclorama Building, Gettysburg National Military Park (reprinted in its entirety, released by the National Park Service, January 1999)

Jump directly to Sections below. Use the "Back" key to return to the top of the document.
1.0 Description of Undertaking
2.0 Description of Efforts to Identify Historic Properties
3.0 Description of Effected Historic Properties: The Landscape
3.2 The Building
4.0 Description of the Effects of the Undertaking on Historic Properties
5.0 Description of Mitigation Measures Proposed
6.0 Description of any Alternatives or Mitigation Measures that were Considered but not Chosen
7.0 Documentation of Consultation with the State Historic Preservation Officer
8.0 Description of Efforts to Obtain and Consider Views
9.0 Planning and Approval Schedule for the Undertaking
10.0 Copies or summaries of any written views

1.0 Description of Undertaking

As a critical portion of its implementation of the draft General Management Plan/Environmental Impact Statement (GMP) for Gettysburg National Military Park, the National Park Service proposes to remove the Cyclorama Building, which has been determined to be eligible to the National Register of Historic Places. This proposal to create an adverse effect upon a National Register eligible structure is not taken lightly, but is based upon a solid foundation of the park's legislative purposes, statement of significance, mission, and mission goals, as stated in the GMP (pp. 5-9), a wealth of historic documentation, and an unprecedented degree of public involvement in the park's planning processes.

Legislative Purpose of Gettysburg National Military Park:

* To preserve the significant topographical, natural and cultural features that were significant to the outcome of the Battle of Gettysburg. (emphasis added)
* To mark the lines of battle, and to preserve the monuments and markers that commemorate the struggle.
* To provide opportunities for people to learn about the Battle of Gettysburg in the full social, political and cultural context of the Civil War and American History.
* To preserve the objects, artifacts and archives that document the battle, its aftermath and commemoration.

Statement of Significance

* Gettysburg National Military Park is nationally significant as the site of the Battle of Gettysburg, the Soldiers' National Cemetery, and the commemoration and preservation of the battleground. The battle was the largest and most costly in human terms to occur on the North American continent. It lessened the Confederacy's ability to successfully wage war and contributed to the ultimate preservation of the United States. The creation of the Soldiers' National Cemetery, and Abraham Lincoln's Gettysburg Address, heightened Americans' sense of the meaning and importance of the war. The national park, inspired by those who experienced the Civil War, preserved major features of the 1863 battlefield and commemorated the valor and sacrifice of participants. These elements make Gettysburg a place where Americans continue to remember and honor those whose struggle led to a united nation.

Mission

* The mission of Gettysburg National Military Park is to preserve and protect the resources associated with the Battle of Gettysburg and the Soldiers' National Cemetery, and to provide understanding of the events that occurred here, within the context of American history. (emphasis added)

The draft GMP provides the long-term management strategies for implementation of the park's mission goals. All of the alternatives in the draft GMP are driven first by the protection, rehabilitation and preservation of resources associated with the battle of Gettysburg, and second by the interpretation of those resources for the benefit of the visiting public. A copy of the draft GMP was provided to the Pennsylvania Historical and Museum Commission and the Advisory Council on Historic Preservation on August 14, 1998. As identified on pp. 75 and 83-84 of the GMP, the park proposes to remove the Cyclorama Building in order to restore the historic landscapes of the Union battle lines of the 2nd and 3rd days of thc Battle of Gettysburg, and to provide better public understanding of the course of the battle. (See Attachment #1, "Draft General Management Plan/Environmental Impact Statement," Gettysburg National Military Park, August, 1998.)

2.0 Description of Efforts to Identify Historic Properties

In 1995, the Mid-Atlantic Regional Office of the NPS completed the List of Classified Structures (LCS) for Gettysburg NMP. The park's LCS, which includes 100 historic structures, does not include the Cyclorama Building.

In 1995, the park began work on documentation to list the significant contributing features of Gettysburg NMP to the National Register of Historic Places. (Although automatically listed on the Register through it status as a National Military Park, no such documentation had ever been produced.) The draft National Register form was completed in the summer of 1996, and submitted to the Pennsylvania State Historic Preservation Officer (SHPO) for review. The SHPO's primary comment was that the NPS should consider nominating the entire battlefield, with all of its appropriate contributing features, as a National Historic Landmark. Due to unresolved discussions within the NPS concerning the appropriateness of such a step, neither the National Register nor the NHL documentation has been completed. Nevertheless, through this effort in 1996, the SHPO and the park reached agreement, for planning purposes, concerning the significant contributing features of the battlefield as listed on the draft NR nomination. Those contributing features did not include the Cyclorama Building.

Simultaneously, the park initiated a Cultural Landscapes Inventory in 1995. The first phase of that effort (the inventory of significant cultural landscapes) was completed in 1997. The principle finding of the cultural landscape inventory was that the battlefield landscapes themselves (i.e., the hills, valleys, fields, forests and streams) were in most cases more significant than the man-made features (buildings, etc.) in influencing both the location and the outcome of the battle. The most significant man-made features were the road networks used by the armies to arrive upon and maneuver upon the battlefield, and remnants of breast works and other field fortifications. The Cyclorama building is not listed as a contributing feature to the historic landscapes of the battlefield.

In preparation of the draft GMP, the park staff further analyzed the changes in the park's historic landscape over the period of 1863 to 1998 (see pp. 29-51). The analysis concentrated on landscape features significant to military action (terrain analysis), landscapes significant to the outcome of the battle (battle action analysis), and landscapes significant to the veterans' commemoration of the battle. Based upon these analyses, the draft GMP recommends restoration of significant historic landscape features within the major battle action areas of the park, in order to both restore and preserve those significant features, and to provide for better public understanding. Cemetery Ridge, the final defensive positions of the Union army on July 2 and July 3, 1863, and the object of repeated Confederate attacks on those days, was determined to be a primary and significant battle action area. Consequently, the draft GMP calls for the removal of modern structures --including the Cyclorama Building, which was constructed almost 100 years after the battle--from those significant historic landscapes.

In December 1995, the NPS prepared a Determination of Eligibility for the Cyclorama Building, in accordance with National Register Bulletin #22, "Guidelines for Evaluating and Nominating Properties That Have Achieved Significance Within The Last Fifty Years." Based upon its evaluation of Criteria Consideration G, the NPS determined that the building had not achieved historic architectural significance since its design in 1958, and had not received scholarly recognition. On May 26, 1996, the Pennsylvania SHPO concurred with the NPS that the Cyclorama Building was not eligible for the National Register of Historic Places. (See Attachment #2, "Determination of Eligibility: Gettysburg Visitor Center and Cyclorama Building," Gettysburg NMP, December, 1995.)

In February 1997, however, the Society of Architectural Historians requested that the Advisory Council on Historic Preservation (ACHP) seek the opinion of the Keeper of the National Register of Historic Places, concerning the building's eligibility. The ACHP acceded to that request, and on September 24, 1998, after reviewing the original determination and subsequent materials, the Keeper determined that the Cyclorama Building was eligible for listing on the National Register of Historic Places under criteria A and C.

3.0 Description of Effected Historic Properties

3.1 The Historic Landscape

The park's existing visitor developments - the Cyclorama Building, the visitor center, and their associated parking lots, pedestrian walks, and ornamental plantings - are situated on Cemetery Ridge, a primary defensive position held by the Union Army of the Potomac during the Battle of Gettysburg. The site is part of a low, broad ridge that extends two miles, from Cemetery Hill on the north to Little Round Top and Big Round Top on the south. On a map, the shape of the ridge and the hills looks like the shank and the eye of a fishhook. The Cyclorama Center and the visitor center occupy parts of what was the David Ziegler farm during the 1863 battle. Ziegler's farm buildings, adjacent to the Emmitsburg Road, no longer stand, but stone walls associated with the boundaries of the farm exist in part, particularly along the Taneytown Road and adjoining the Brian farm. An orchard of fruit trees, belonging to an adjacent farm outlot, occupied a meadow area north of the Leister farm buildings (Meade's Headquarters) and adjoining the Taneytown Road; this site is now the lawn east of the Cyclorama Building. The most prominent feature of the Ziegler farm, however, was the grove of oaks, cherries and poplars which dominated the crest of the ridge and spilled over its eastern slope towards Taneytown Road. This grove sheltered Union troops of the First and Second Corps, as well as artillery batteries, and was splintered by shell fire during the latter two days of the battle when Confederate forces concentrated their efforts on capturing Cemetery Hill, now the site of the National Cemetery.

During the fighting of July 2 and 3,1863, this site was occupied by infantry of Major General Alexander Hays' Third Division, Second Corps; by infantry of Major General John Robinson's Second Division, First Corps; and by artillery guns of the 9* Massachusetts Battery and Battery I, First U.S. Artillery. Although major Confederate attacks were anticipated, but not made, on this portion of the Union line on the evening of July 2, unending and deadly skirmishing and sharpshooting occurred along and west of the Emmitsburg Road in front of this position.

Throughout the day, troops were constantly on alert, under fire from Confederate artillery, and in movement: to the skirmish line, to the Union left to bolster crumbling lines there, and, as darkness fell, to stem breach in the Union lines behind the Ziegler's Grove position at East Cemetery Hill.

The skirmishing and artillery firing along the Ziegler's Grove front continued throughout the morning of July 3. The fire to and from the guns of the two Union batteries intensified during the post-noon cannonade that preceded the great infantry assault which would be known as the "Pickett-Pettigrew Charge" or "Longstreet's Assault." Casualties among the U.S. Regular battery were high, and were extreme among the Confederate troops--fewer than half the approximately 14,000 men who made the advance returned to their own lines.

In short, almost 100 years after the Batt1e of Gettysburg, the Cyclorama Building was constructed on the heart of the Union defensive lines of July 2 and July 3, in Ziegler's Grove. On the grounds currently covered with the concrete, brick and asphalt of the Cyclorama Building, the visitor center, and their roads and parking lots, 971 Union and Confederate soldiers were killed, wounded, and captured. It is indeed the most significant historic landscape at Gettysburg NMP, and may well be some of the most hallowed ground in the United States.

Previous planning work over the last several decades has acknowledged the problem presented by the intrusion of the Cyclorama Building and visitor center on these significant historic landscapes, but no solutions had been found. Even the Advisory Council on Historic Preservation, in its June 1977 publication entitled "A Plan to Preserve the Historic Resources of the Gettysburg Area of the Commonwealth of Pennsylvania," recommended removal of the visitor center and "relocation of the Cyclorama Center," both of which the ACHP considered to be "intrusions near the cemetery and the climactic scene of the battle..." (pg. 6-7).

3.2 The Building

The Determination of Eligibility Notification from the Keeper of the National Register states, in its entirety, that:

The Cyclorama Building is eligible for the National Register of Historic Places for its exceptional historic and architectural significance under criteria A and C. Constructed in 1958 [sic] as part of the National Park Service's massive and influential Mission 66 program, the Cyclorama Building is one of only five of the newly conceived building type, the Visitor Center, designed for the National Park System by noted, world class architects.

The Mission 66 program, a nearly billion dollar, ten year master planning and construction effort, was an exceptionally important undertaking in the history of conservation and the architecture of the National Park System. Designed to meet dramatically increased park visitation following World War II, and to coincide with the 50th anniversary of the National Park Service in 1966, Mission 66 had a profound impact on the physical infrastructure of the National Parks. Envisioned as a bold and forward-looking initiative, Mission 66 adopted modernism as its creed.

Reflecting a much more visitor-oriented management operation, the Mission 66 program conceived an innovative new building type--the Visitor Center--to centralize the management of visitors and interpretation of park resources. Strategically placed at centers of primary intaest in parks and functioning as the hub of interpretive programs, visitor centers were collaborative designs of architects, landscape architects and museum specialists. Often, this collaboration involved professionals both within and outside the Service. Of the approximately 100 Visitor Centers eight [sic] built or converted from existing buildings (79 newly constructed, 21 refurbished) the National Park Service selected five parks to receive the services of acclaimed architects:

* Gettysburg Visitor Center (Cyclorama Building) at Gettysburg National Military Park, Gettysburg, PA; Richard Neutra & Robert Alexander, Los Angeles, CA, architects, 1958.
* Visitor Center, Wright Brothers National Memorial, Cape Hatteras National Seashore, Manteo, NC: Mitchel, Cunningham & Giurgola, architects, 1958. Listed in the National Register as a contributing resource in the Wright Brothers National Memorial nomination, 2/26/98.
* Quarry Visitor Center, Dinosaur National Monument, vicinity of Jensen, UT; Anshen and Allen, San Francisco, architects, 1956-57. Listed in the National Register as a component of the Dinosaur National Monument MRA, 12/19/86.
* Headquarters Building (Beaver Meadows Visitor Center/Administration Building), Rocky Mountain National Park, Estes Park, CO; Taliesin Associated Architects, 1965-66. Listed in the National Register as a component of the Rocky Mountain Park Utility Area (Rocky Mountain national Park MRA) as of 3/18/82.
* Painted Desert Community (including the Visitor Center), Petrified Forest National (Monument) Park, AZ; Richard Neutra & Robert Alexander, architects, 1959-61.

From his earlier work designing innovative international style residences in California to his later commissions on major public buildings such as the Cyclorama Building, the U.S. Embassy in Karachi, Pakistan, and the Los Angeles Hall of Records, Neutra is recognized as a master architect of Modern design by scholars in numerous publications. The recipient of many design awards and citations, in 1977 Neutra was posthumously honored by the American Institute of Architects, which awarded him its Gold Medal for lifetime achievement.

While it is undebatable that Neutra has been highly and widely acclaimed for his earlier residential designs for some time, it is not unusual for the significance of his later work to be gaining attention with the passage of time. Scholars are now placing his later works too into the context of modern architecture of the period. s such, the Cyclorama Building is a rare example of Neutra's institutional design on the east coast and one of his very few Federal commissions. While not currently analyzed in detail in publications, it is one of a very few of his later works often mentioned or illustrated. Similarly, the evolving scholarship on the history and impact of the Mission 66 program on design in the parks clearly indicates the seminal importance of the visitor center as a building type and of the examples designed by master Modern architects mentioned above, including the Cyclorama Building. ("Determination of Eligibility Notification," Keeper of the National Register, September, 1998.)

3.3 The Gettysburg Cyclorama

The Gettysburg Cyclorama was completed in 1884 by the celebrated cyclorama painter Paul Dominique Philippoteaux. The colossal panoramic painting depicts Pickett's Charge, the last major offensive strike by General Robert E. Lee's Army of Northern Virginia against Union forces on the last day of intense and bloody fighting at Gettysburg. The painting (the 2d of four produced by Philippoteaux) was displayed in Boston from 1884 to 1891. It was than stored until purchased in 1910 by Albert Hane, who brought it to Gettysburg in 1913 to exhibit during the 50th anniversary of the battle. From 1913 to 1960 the painting was exhibited during the summer months in a building on Cemetery Hill. The painting was acquired by the NPS in 1942, and was installed in the purpose-built Cyclorama Building in 1961.

In 1944, the Acting Secretary of the Interior signed an order designating the Cyclorama of Gettysburg to be a National Historic Object, under the authority of the Historic Sites Act of 1935. As such, the Gettysburg Cyclorama is considered to be eligible to the National Register of Historic Places.

Over the past three years, the NPS has consulted with three painting conservators' concerning the condition of the Cyclorama painting, and recommendations for preservation treatment. [listed in footnote as Wim Muyres, Painting Conservator, Nethalands, 1995; Perry Huston, Painting Conservator, Perry Huston & Associates, Fort Worth, Texas, 1998; Tom Ferguson, Painting Conservator, Atlanta Cyclorama, Atlanta, Georgia, 1998] The conservators generally agree that the painting is in very poor condition. The paint layer is actively flaking with numerous small losses in several areas, most notably along the fold lines created by improper hanging (see below). The bottom edge of the painting is in poor condition with cracking and lifting of paint in large areas. Although some of these problems are the result of previous conservation work undertaken in 1959-1961 (in preparation for installation in the Cyclorama building), the other major structural and environmental problems threatening the life of the painting are directly associated with design inadequacies and failures of the Cyclorama building.

When installed in the Cyclorama Building, the painting was improperly mounted, using a technique that does not permit the painting to assume its natural parabolic shape. Because of this, pronounced dimensional distortion has resulted in cleavage, tenting, flaking and loss of the paint layer. Unfortunately, the size of the present cylindrical Cyclorama exhibit area is too small to accommodate the painting if it were mounted properly and returned to its original parabolic shape. The cylindrical drum is too small to accommodate the expanse of the painting plus a mounting support system, access to the back of the painting (for preservation maintenance) and adequate insulating space between the painting and the exterior wall. These physical inadequacies of the Cyclorama building cannot be corrected without complete demolition and reconstruction of the entire drum area of the building. The painting conservators who have examined the painting recommend that restoring the painting to its natural, and intended, hyperbolic shape, is the highest priority for the future preservation of the painting. (See attachment #3, "Conservation Considerations and Recommendations Regarding Exhibition of the Gettysburg Cyclorama," Northeast Regional Conservation Center, NPS, November, 1998.)

Ever since being installed in the Cyclorama building, the painting has been subjected to excessive moisture conditions, as the foundations of the building began to settle. The problems include shear and stress cracks, fractures, rusting rebar, and cracks in the terrazzo and thermal pane glass windows. The heating and air conditioning ductwork in the lower part of the drum are installed under the floor slab. Building settlement has put extreme stress on these ducts, which fill with water during heavy rains. Therefore, during wet weather, the ducts pump an excessive amount of humidity into the building, and introduce mold and mildew when the weather is dry. The roof above the Cyclorama exhibit gallery has historically leaked due to inherent design problems, and has been replaced several times already, most recently in 1997. Due to the building's design and the construction techniques utilized, these basic structural and foundation problems cannot be resolved without near-complete demolition and reconstruction of the building.

Exposure to extremes and high fluctuations in relative humidity have long been viewed as the second most serious detrimental factor to the preservation of the painting. The original climate control system installed when the building proved inadequate (partially due to the building failures described above), with variations of 40% in relative humidity. The system was upgraded by the NPS in the mid 1970s and equipped with humidification capacity. In the mid-1980s it was upgraded again, with the addition of a 60-ton air conditioning unit (on the roof). Unfortunately, the humidification system has never worked properly and the reheat capacity of the conditioners is not sufficient to control high relative humidity. The wide fluctuations in relative humidity continue to cause the organic materials in the laminate structure of the painting to contract and expand, resulting in flaking paint.

4.0 Description of the Effects of the Undertaking on Historic Properties

4.1 The Historic Landscape

Preservation of the existing modern landscapes of the park means that non-historic intrusions would continue to dominate the historic setting of the 1863 battlefield and its commemoration. Examples of these intrusions include the Cyclorama Building. (GMP, p. 221) Retention of the Cyclorama Building in the heart of the principle historic landscape of Zeigler's Grove would prevent the NPS from restoring that landscape to its historic appearance. The decision--or undertaking--not to remove the Cyclorama Building would be contrary to the park's mission goal of restoring the historic landscapes and would be a decision to retain a modem intrusion in the heart of a nationally-significant historic landscape. The NPS has applied the criteria of effect and adverse effect to this alternative, and has determined that it would have an adverse effect upon the integrity of the design, setting, feeling and association of the historic landscape of Ziegler's Grove, and an adverse effect through the continuation of a visual element which is out of character with the historic landscape.

Conversely, the NPS has determined that the removal of the Cyclorama Building (and the visitor center) would result in a decided beneficial impact to the historic landscapes of the Union battle lines of July 2 and July 3, 1863.

4.2 The Historic Structure

The Keeper of the National Register has determined that the Cyclorama Building is eligible for the National Register of Historic Places under criteria A and C. Criteria A, "associated with events that have made a significant contribution to the broad patterns of our history," is due to the building's design and construction "as part of the National Park Service's massive and influential Mission 66 program. . ." Criteria C, "the work of a master," is associated with the building's design by Richard Neutra. The NPS has applied the criteria of effect and adverse effect to the proposal to remove the Cyclorama Building, and has determined that it would have an adverse effect upon the characteristics which make the building eligible to the National Register.

This adverse effect is mitigated, however, by several factors. The original purpose of the building was described in the 1956 prospectus, which stated that "There is urgent need for museum development at Gettysburg, especially for a building to properly house, preserve, and interpret the great cyclorama painting; to preserve other battle relics; and through the media of exhibits to better explain and interpret the events which happened here." (Determination of Eligibility, p. 40, emphasis added) However, due to a combination of factors, the building either no longer serves, or is unable to serve, any of those original purposes.

* A part of the association of the building with the Mission 66 program is its originally intended use as a visitor center for Gettysburg NMP. However, upon the purchase of the former Rosensteel museum building in 1971, the NPS ceased using the Cyclorama building as the park's visitor center. Since 1971, all visitor center functions--information, orientation, etc.--have been housed in the current visitor center. Due to the current visitor center's size, location, and design, factors that enable it to handle larger numbers of visitors, it provides superior visitor service than can the Cyclorama building. In addition, all of the park's museum collection and museum exhibits were transferred from the Cyclorama building to the visitor center following 1971, due to the latter building's size and ability to house both the collections and the exhibits. Consequently, the Cyclorama building's association with the Mission 66 program has already lost some of its original significance.
* The major design purpose of the Cyclorama building was to display and preserve the Cyclorama Painting. Due to inherent design flaws and insufficiencies, however, the building has failed to perform in its intended function. Indeed, due to its design, it cannot perform in that function. Consequently, the integrity of the design of the Cyclorama Building has already been effected, due to the building's inability to perform in its primary design function.

4.3 The Gettysburg Cyclorama

Continued use of the Cyclorama Building to house and display the Gettysburg Cyclorama would have an adverse effect upon this National Historic Object. The painting would continue to be subjected to undue stress caused by its improper hanging, and extreme fluctuations of humidity caused by the building's inadequate humidification systems.

Implementation of the preferred alternative would have a beneficial effect upon the preservation of the Gettysburg Cyclorama. In accordance with the draft GMP, the NPS proposes to conduct a thorough condition assessment of the painting, prepare a thorough treatment plan, conduct complete restoration of the painting, and display it in a new visitor center/museum complex. The new complex would, of course, provide for proper handing of the painting and would include adequate climate control and humidity control features.

5.0 Description of Mitigation Measures Proposed

The NPS proposes the complete recording of the current condition of the Cyclorama Building, to include photographs and measured drawings. Recordation of the building would be done to Historic American Building Survey [sic] (HABS) standards, and copies of the recordation documentation would be provided to HABS and all other interested recipients.

6.0 Description of any Alternatives or Mitigation Measures that were Considered but not Chosen

6.1 1996 Development Concept Plan/Environmental Assessment

In 1996, the NPS prepared a Development Concept Plan/Environmental Assessment for Collections Storage, Visitor and Museum Facilities at Gettysburg NMP (DCP). (see Attachment #4) The DCP was driven by four major park goals (p. 8):

# 1. Protect the park's collection of museum objects and archives

2. Preserve the Cyclorama Painting

3. Provide high quality interpretation and educational opportunities for park visitors

4. Rehabilitate Ziegler's Grove and the High Water Mark of the Battle

The DCP considered and evaluated four options:

Option A: No Action. This option would have continued the existing storage conditions, or the status quo. Collections storage, museum exhibits and visitor facilities would remain in their current locations and buildings. This option would continue adverse impacts upon the museum collection, the archival collection, the Cyclorama Painting, and modern intrusions (visitor center, Cyclorama Building, roads and parking) on the historic landscapes.

This option would not achieve any of the park's four objectives.

Option B: A New Collections Storage Facility. This option proposed building a new collections storage facility on a site within the area of consideration. This facility would meet minimum NPS curatorial storage requirements for the park's collection of museum objects and archives. The visitor center and Cyclorama buildings would remain unchanged, and in their current uses, except for the relocation of collections storage to the new facility.

This option would achieve park objective #1 above, but would not achieve objectives #2 through #4.

Option C: New Cyclorama/Collections Storage Facility and Rehabilitated Visitor Center/Museum.

This option would develop a combined collections storage and Cyclorama Center on a site within the area of consideration, and would rehabilitate the park's existing visitor center and museum. It combined the collections storage facility described in Option B with a new cyclorama gallery, an auditorium/multipurpose room, park library, and interpretive offices. The old Cyclorama Building would be removed and its site would be rehabilitated to reflect the historic landscapes of the battlefield setting. The visitor center would be rehabilitated and its museum and exhibits upgraded to tell the story of the Gettysburg Campaign in its context of the Civil War.

This option would achieve park objectives #1 and #2, and would partially achieve objectives #3 and #4.

Option D: (The Preferred Option) New Visitor Center and Museum Complex. This option would provide a new complex to house the park's Visitor Center, museum, cyclorama painting and collections storage, located on a site within the area of consideration. All visitor functions in the existing buildings would be relocated. Collections storage would be incorporated into the new facility. The new museum complex would allow the appropriate conservation and preservation of the cyclorama painting. New permanent museum exhibits would allow the park to tell the story of the Gettysburg Campaign in its broad context of the Civil War and American history. This option proposed removing the existing visitor center and Cyclorama Building and rehabilitating their sites to reflect the historic landscapes of the battlefield setting.

This option would completely achieve park objectives #1 through #4.

Option D was the NPS's preferred alternative for the DCP/EA, which was released for a 45-day public review period in April 1996. The NPS selected Option D as its preferred alternative primarily because it was the only alternative that completely satisfied all four of the park's main objectives outlined above. In particular, when weighing the alternatives for the Cyclorama Building, the primary objective was to provide long-term preservation and care for the Cyclorama Painting.

The park received 59 written comments from the public during the 45-day public review period, the majority of which supported the park's preferred alternative. The majority of the comments received supported the park's objective of removing the visitor center and Cyclorama Building in order to rehabilitate the historic landscapes of the battlefield. None of the public comments indicated concerns with the park's proposal to remove the Cyclorama Building. The Pennsylvania SHPO provided constructive comments upon the DCP, along with a concurrence in the park's determination that the Cyclorama Building was not eligible to the National Register of Historic Places.

6.2 Other Options Considered but Rejected - Rehabilitation of the Building for Continued Use

When considering the options for preservation of the Cyclorama Painting, the NPS did consider the possibility of rehabilitating of the Cyclorama Building itself. However, this option was rejected after detailed study for several reasons. The rehabilitation of the Cyclorama Building would require solutions to several major design problems, the practicality of which could not be determined and the cost of which seemed excessive. The rehabilitation of the building would require almost complete demolition and reconstruction, thereby effecting its integrity of design and materials. Finally, the NPS believed that the impacts upon the setting of the historic landscapes of the battlefield were greater than could be acceptable for the park or its constituent public.

One critical design problem is the lack of fire exits in the cyclorama gallery. The gallery, an assembly area with a capacity of 175, requires two fire exits. Currently, the only means of egress is via a single 300-foot ramp that does not constitute an acceptable fire-rated exit The problem is complicated by the cyclorama painting, which covers 100% of the wall space within the gallery. To place even one fire stair, no matter what its configuration, within the space would severely compromise the interpretive program and the 360% view required from the viewing platform.

The cyclorama gallery and the rooftop observation deck are both reached via long ramps. The ramp to the observation deck is 200 feet and the one to the cyclorama gallery is 300 feet The Uniform Federal Accessibility Standards require a 5-foot landing for every 30-inch rise, effectively every 30 feet. Both of these ramps are poured-in-place concrete which would require complete demolition and reconstruction to meet the code requirements. The proper ramp profiles would extend each ramp between 35-feet to 50-feet beyond their existing restricted footprints, severely compromising the design and function of these important areas.

The building began to settle not long after construction. This resulted in cracked glazing panels, cracked terrazzo floors in the lobby, the permanent closure of a 45-foot by 16-foot sliding glass window wall at the amphitheater, continual water leaks, cracked structural concrete, and exposed steel reinforcing bars. Because the building is poured-in-place concrete, it cannot be jacked up. Even with extensive soil and foundation consolidation, and repairs of the cracked areas, the sliding window wall cannot be repaired and the deformations of the structure are permanent

The restoration of the cyclorama painting presents the final unsolvable issue. Proper conservation of the painting would require restoring its original hyperbolic shape. This would eliminate the large folds that currently exist in its present incorrect installation. In the proper hyperbolic profile, the lower edge of the painting has a larger circumference than the top. Currently, there exists, on average, approximately 3 feet of space between the back of the painting and the structural concrete piers of the cyclorama drum. Also, large heating, ventilating and air conditioning ducts are installed between the painting and the exterior wall. When the painting is properly restored, it would not be possible to reinstall it within the current space, if it were properly hung and if adequate space was reserved for periodic inspection and treatment of the painting.

In 1996, the cost of construction required to correct the design deficiencies in the Cyclorama Building for continued public use was estimated to be $8,127,213. (This estimate did not include the cost of demolition and reconstruction of the display drum portion of the building, since the NPS did not realize in 1996 that the painting could not be properly rehung within the current structure.) Even if these secondary building deficiencies were corrected, however, the size of the cyclorama drum could not be expanded without complete demolition and reconstruction of almost the entire structure. Since the current drum is insufficiently sized to allow the painting to be properly hung and preserved, the option of rehabilitating the Cyclorama Building as an exhibit gallery for the Cyclorama Painting was rejected.

6.3 Other Options Considered but Rejected - Rehabilitation of the Building for Adaptive Use

Once the decision was made that the Cyclorama Building could not be effectively rehabilitated for continued display of the painting, the NPS was unable to identify any other appropriate public uses for the building. In the future, all visitor services would be housed in the new visitor center/museum complex located well away from the prime historic areas of the park. The NPS considered other non-public uses for the structure, including administrative office space. However, a very minor percentage of the building's square footage was designed or is readily usable as office space, as compared to the space that was designed for public use and display of the painting.

Although rehabilitation of current office spaces for long-term administrative use would be relatively inexpensive (+/-$400,000), continued use of those spaces would be expensive given the annual operating costs of heating and maintaining the entire structure, with only a fraction being utilized. Rehabilitation of the spaces designed for public use and display of the painting would be considerably more expensive (+/-$7,000,000). This option, even if cost-effective, would give the park far more administrative space than needed, since both headquarters and interpretive staff would be located in the proposed visitor center/museum complex. Finally, the NPS determined that it would be inappropriate to house administrative staff in a structure which represents a visual intrusion on the historic landscapes that the park was created to preserve.

7.0 Documentation of Consultation with the State Historic Preservation Officer

* February 21, 1995 - NPS requests consultation with Pennsylvania SHPO on proposal to consider the concept of a public private partnership to build a new museum.
* April 18, 1995 - NPS requests consultation with Pennsylvania SHPO on the (first) draft development concept plan (DCP) for the Gettysburg Museum of the Civil War. (The draft plan called for removal of the Cyclorama Building.)
* May 3, 1995 - SHPO provides comments on draft DCP.
* June 15, 1995 -NPS responds to SHPO comments.
* September 6, 1995 - Scoping meetings with SHPO, on planning process for new facilities.
* September 13, 1995 - Scoping meetings with SHPO, on planning process for new facilities.
* December 7, 1995 - NPS requests SHPO consultation on formulation of alternatives for new DCP.
* December 12, 1995 - Consultation meeting held with SHPO.
* December 20, 1995 - Consultation meeting held with SHPO.
* May 3, 1996 - NPS request SHPO comments on draft DCP/EA for Collections Storage, Visitor & Museum Facilities. (Option 4, the Preferred Alternative, recommends removal of the Cyclorama Building.)
* May 28, 1996 - SHPO comments on draft DCP/EA.
* February 5, 1997 - SHPO participates in park's Government Performance Results Act (GPRA) strategic planing process to generate statements describing the park legislative purpose, significance, mission, and mission goals.
* February 26, 1998 - SHPO participates in park's GPRA planning meeting.
* March 19, 1997 - SHPO participates in park's GPRA planning meeting.
* May 22, 1997 - General Management Plan (GMP) scoping newsletter sent to SHPO (and ACHP).
* July 10, 1997 - SHPO attends public scoping meeting for draft GMP.
* August 4, 1997 - NPS sends formal letters to SHPO and ACHP, requesting consultation on GMP. (NPS also transmitted the GPRA strategic management plan to ACHP.)
* August 21, 1997 - SHPO attends public scoping meeting for draft GMP.
* October 18, 1997 - SHPO attends public scoping meeting for draft GMP.
* October 18, 1997 - GMP newsletter sent to SHPO and ACHP.
* December 18, 1997 - SHPO attends GMP workshop meeting.
* December 30, 1997 - GMP newsletter sent to SHPO and ACHP.
* March 4, 1998 - SHPO attends GMP workshop meeting.
* March 20, 1998 - GMP newsletter sent to SHPO and ACHP.
* March 25, 1998 - NPS sends letter to ACHP (with copy to SHPO), request [sic]early consultation on potential adverse effect of removal of the Cyclorama Building, if the Keeper of the National Register should overturn the NPS's and SHPO's determination that it was not eligible to the National Register.
* May 1, 1998 - SHPO given update on status of GMP, as part of annual PMOA site review of park projects.
* June 23, 1998 - GMP newsletter sent to SHPO and ACHP.
* August 14, 1998 - Draft GMP/EIS sent to SHPO and ACHP.
* September 22, 1998 - SHPO and ACHP attend meeting at park to discuss draft GMP.
* October 16, 1998 - SHPO comments on draft GMP received.

8.0 Description of Efforts to Obtain and Consider Views

The NPS has conducted an unprecedented public involvement strategy, as plans for the new visitor center and museum complex were first initiated, and then folded into the park's draft GMP. Public involvement started in March 1995, with the release of the first DCP for a new museum complex (which first proposed the removal of the Cyclorama Building). Between that date and the close of the public review period of the draft on October 17, 1998, public involvement opportunities consisted of:

* The park conducted 48 public scoping meetings that included local governments and other interested parties.
* The park conducted 3 open houses (to view the behind-the-scenes damage to the Cyclorama Painting caused by the inadequate design and building failures of the Cyclorama Building, and the improper hanging of the painting in the building).
* The park provided 200 days of public review of draft plans (both DCPs and GMP)
* The park conducted 37 public workshops and meetings.
* The park mailed 8 newsletters to everyone on the park's mailing list.
* The park compiled a mailing list of over 3,800 interested parties.
* The park received 3,485 written public comments during the public review periods for the draft DCPs and during the formulation (scoping) of the GMP.
* 85% of comments received were in favor of an alternative that requires removal of the Cyclorama Building in order to restore the park's significant historic landscapes.
* The park received 503 written public comments received during review of draft GMP. 70% of comments received were in favor of an alternative that requires removal of the Cyclorama Building, in order to restore the park's significant historic landscapes.

In addition, the park staff has conducted approximately 25 congressional briefings on the draft GMP, and made over 25 presentations to Civil War Roundtables and similar interested groups.

9.0 Planning and Approval Schedule for the Undertaking

Public review on the draft GMP/EIS closed on October 17, 1998. The park staff, assisted by staff from the Northeast Regional Office, the Denver Service Center, the Washington Office, the Office of the Solicitor (Department of the Interior), and professional consultants for economic, traffic, and soils and water analysis are in the process of reviewing, analyzing, and responding to the 500+ public comments received.

Based upon the analysis of public comments, the draft GMP/EIS will be revised as appropriate, for the review and approval of the Regional Director and Director of the NPS. This process is scheduled to be completed by the end of December 1988. [sic] Upon approval of the Director, the final GMP/EIS will be printed and distributed to all members of the public who submitted written comments upon the draft plan. A 30-day no action period will begin on the day the final GMP/EIS is distributed. At the end of the 30-day no action period, the Record of Decision may be signed.

Due to the very late date of the Keeper's determination that the Cyclorama Building was eligible for the National Register of Historic Places (42 months after the NPS's first proposal to remove the building, 28 months after the SHPO concurred with the NPS's determination that the building was not eligible, and 40 days after the 60-day public review period for the draft GMP began), the NPS respectfully requests that the Advisory Council on Historic Preservation coordinate its review of the proposed removal of the Cyclorama Building to the fullest extent possible with the review of the draft GMP/EIS.

10.0 Copies or summaries of any written views

The NPS received 3,485 public comments during the development and review of the Development Concept Plans that proposed removal of the Cyclorama Building, and during the formulation of the General Management Plan. As indicated above, fully 85% of those comments strongly supported the implementation of the park's goals and objectives, including the removal of the Cyclorama Building in order to restore the significant historic landscapes of the battlefield. Although copies of those comments may be made available if necessary, the preferred alternative (C) of the draft GMP itself is the best summary of public comments received.

The NPS received 503 written comments during the 63-day public review period of the draft GMP/EIS. Again, the great majority (70%) of those comments strongly supported the park's preferred alternative. With the exception of those already listed as interested parties in this consultation, few--if any--of the public comments which opposed the park's preferred alternative indicated that their opposition was due to the removal of the Cyclorama Building.

Attachments:

"Draft General Management Plan/Environmental Impact Statement," Gettysburg National Military Park, August 1998.

"Determination of Eligibility, Cyclorama Building," Gettysburg National Military Park December 1995.

"Conservation Considerations and Recommendations Regarding Exhibition of the Gettysburg Cyclorama," Brigid Sullivan, Chief Conservator, Northeast Regional Conservation Center, NPS, November 1998.

"Draft Development Concept Plan/Environmental Assessment, Collections Storage, Visitor Museum Facilities," Gettysburg National Military Park, April 1996.


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