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Return to: Documents Determining Significance | Timeline of Events Letter of response
to Gettysburg NMP Section 106 Case Report January 19, 1999 By Fax Dr. John A. Latschar Re: Comments on Section 106 Case Report, Cyclorama Building Removal Dear Dr. Latschar: Thank you for providing the National Trust for Historic Preservation the opportunity to comment on the National Park Service's Section 106 Case Report for the proposed demolition of thc Cyclorama Building, as a central element of the Park Service's implementation of the draft General Management Plan/Environmental Impact Statement (GMP/EIS) for Gettysburg National Military Park. The recent determination by thc Keeper of the National Register of Historic Places that the Cyclorama Building is eligible for inclusion in the National Register adds a new element to the GMP/EIS analysis, which in its current draft form evaluates the relative impacts of GMP alternatives on a broad number of cultural resources within the Gettysburg National Military Park and its environs, but does not take into account the effects of the GMP alternatives on the Cyclorama Building as a cultural resource in its own right. Recognition of the historic status of the Cyclorama Building affects, in a fundamental way, the principal management choices to be made by the National Park Service for the Gettysburg Battlefield. At the same time, the proposed demolition of the Cyclorama Building must continue to be evaluated in the context of the other significant historic resources identified in the Draft GMP, including the historic landscape of the battlefield and thc Cyclorama painting itself, which is a designated National Historic Object. The relationships between these three historic elements--the Gettysburg historic landscape, the Cyclorama Building, and the Cyclorama painting--present issues of interpretation and preservation that are extremely complex. The comments that follow identify several aspects of the Park Service’s Section 106 report which we believe should be explored or explained in further detail during the Section 106 consultation process. It is importent to clarify that the points raised here are not intended as a means of advocating that the ultimate decision of thc Park Service should be to retain the Cyclorama Building. Rather, as a matter of principle, we believe that the historic and architectural significance of the Cyclorama Building requires the Park Service to ensure that thorough consideration is given to all relevant factors and alternatives--and particularly whether any alternative would permit retention of the Cyclorama Building in a manner that would not significantly detract from the Park Service's goal of restoring the principal character-defining elements of the battlefield landscape. The Section 106 consultation process encourages agencies to explore ways in which an undertaking may be modified in order to avoid or mitigate its adverse effects on historic properties. When a historic property has been determined to be of "exceptional" historic and architectural significance, it is the view of the National Trust that this effort to consider alternatives should be a particularly rigorous one. In this case, thc Keeper of the National Register has determined that the Cyclorama Building is of "exceptional" significance (a necessary prerequisite for eligibility of a structure less than 50 years old). The Park Service nonetheless proposes to demolish the Cyclorama Building. While acknowledging the determination of significance of the Cyclorama Building made by the Keeper, the Park Service has effectively made the case that the character-defining features of the 1863 battlefield, and in particular the area of Ziegler's Grove, are of a higher level of historic significance, and should be restored in order to enhance the public interpretation of the battlefield. We strongly agree with the Park Service's determination that primary significance should be accorded the original battlefield landscape. Nonetheless, we believe that several aspects of the Section 106 Report--which essentially sets forth the Park Service's decision that the demolition of the Cyclorama Building is necessary in order to achieve this goal--should be addressed more fully by the Park Service before a final decision is made. We suggest that the following issues be addressed in consultation with the Advisory Council task force recently appointed by Chairman Slater. First, historic landscapes, by their very nature, evolve and grow organically over time, and the "restoration" of a historic landscape may constitute a fairly speculative modern enterprise. The historic landscape at Ziegler's Grove may present especially difficult problems for a proposed "restoration" because of the extent to which the 1863 landscape has been altered. (The Gettysburg National Military Park's initial determination of eligibility describes the extensive, and somewhat confusing, evolution of the character of this portion of the battlefield, from 1863 to modern times.) The Draft GMP (at pp. 55-56) correctly acknowledges that the landscape resulting from a restoration would not fully reflect the conditions present in 1863, but concludes that such a restoration could convey the essential features that define the historic character of the landscape, in order to allow visitors a more powerful appreciation of how the 1863 landscape influenced thc course of thc battle and affected individual units and soldiers. Because the conclusion of the Section 106 Report is so closely tied to the goal of restoring thc character-defining features of the 1863 landscape, it would be helpful to understand the specific impacts of the Cyclorama Building alone--i.e., not as part of the larger visitor center complex--on that landscape, and the specific restoration measures that the Park Service expects to take as they would relate to the area occupied by the Cyclorama Building. Second, subsequent changes to a historic landscape may become historically significant in their own right, and worthy of preservation. This does not necessarily mean that they must be preserved (and, indeed, the Park Service's guidelines for the treatment of historic landscapes, in Preservation Brief No. 36, expressly recognize that it may be appropriate to restore a landscape's character-defining features to a specific point of time without reflecting its later evolution). The choice as to treatment, however, should be made with the full understanding of the significance of the original and the altered landscapes. In this case, we agree with the Park Service's determination as to the primary importance of the 1863 landscape, but we disagree with the report’s suggestion (in section 4.1) that the cultural landscape features relating to the Cyclorama Building are simply "non-historic intrusions " Given the Cyclorama Building's "exceptional" significance, its intentional placement and design to "ennoble the site of the battle with the building" (as noted in the Gettysburg National Military Park's initial determination of eligibility, p.41), and the site's relationship to the panoramic perspective of the historic Cyclorama Painting (which would itself be affected by removal of the painting to a different location), the significance of the later cultural landscape must be acknowledged and addressed. Third, it is important that the actions of the National Park Service at Gettysburg be guided by, and consitent with, the Secretary of the Interior's Standards for the Treatment of Historic Properties (and the principles set out in Preservation Brief No. 36, regarding the protection and management of cultural landscapes). In this regard, it would facilitate public understanding of the Park Service's proposal if the Section 106 Report explicitly addressed the application of the Secretary's Standards to the landscape restoration plans set out in the GMP, including the proposed demolition of the Cyclorama Building. It is unclear, for example, whether the Park Service's restoration plan for Ziegler's Grove are entirely consistent with the Sectetary's Standards for Restoration, considering that they would still retain certain natural features and commemorative structures not present in 1863. (Retention and preservation of changes that have become significant in their own right are recommended under the Standards for Preservation or Rehabilitation, but discouraged under the Standards for Restoration or Reconstruction.) It would be helpful for the Park Service to articulate how those standards would apply to the restoration of significant character-defining features of the cultural landscape, while permitting the retention of certain (but not all) later additions to the natural and man-made landscape, which may have historical significance in their own right. In summary, the National Trust supports the National Park Service’s position that primary significance should be accorded thc original battlefield landscape. We also agree that the removal or relocation of the existing visitor complex would help the Park Service meet its objectives of restoring the character-defining features of part of the historic landscape associated with the Battle of Gettysburg, and improve public understanding of the Battle. Because the Cyclorama Building is eligible for the National Register as a structure of "exceptional" significance, however, we believe that the Park Service's case for demolition of this particular building should be a strong one. Assuming that the Park Service thoroughly addresses the issues raised in this letter as it continues the Section 106 consultation process, the National Trust is prepared to fully support the final decision of the Park Service. Should the National Park Service ultimately choose to proceed with the demolition of the Cyclorama Building as part of its implementation of the GMP, and its relocation of visitor facililies away from this significant area of the battlefield, we of course concur that complete HABS documentation of the Cyclorama Building should be carried out as an appropriate mitigation measure. But in our view, the "exceptional" significance of the building may warrant additional mitigation. At a minimum, we would strongly recommend that suitable interpretation of the history and architecture of the Cyclorama Building, and the history of the landscape changes in the area of Ziegler’s Grove, be included in the new visitor center and museum complex, and that complete HABS documentation of the Cyclorama Building be made available at those facilities. Should the undertaking proceed, we recommend that the Park Service consider other creative mitigation measures in consultation with the Advisory Council. We appreciate the opportunity to comment on this important and difficult decision for the future of Gettysburg Battlefield, and we thank you for considering the National Trust's views. We look forward to consulting further with the Park Service as you move forward to evaluate the complex preservation issues presented by this extraordinary site. Sincerely, /s/ Richard Moe President cc: Mr. Robert G. Stanton,
Director, National Park Service
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