Friday, October 12, 2007

Letters Concerning the Scope of Review for an Art Museum

Here are two letters to the Presidio Trust to recommend the scope of the environmental review concerning the proposed 100,000 square foot art museum. They will go into the record. Names have been deleted. What are your comments on these letters?

RE: Comments on Proposed EIS for a “Public Museum at the Presidio - Main Post”

Dear Mr. Pelka,
In response to the September 24, 2007 public meeting and the August 8, 2007 Notice of Intent to prepare an EIS, I submit the following comments regarding the construction of a museum in the Presidio’s Main Post.

I am delighted that the Presidio is at long last entertaining the notion of a museum. Historic interpretation of this unique National Historic Landmark District has been glaringly absent for many years. While the “Notice of Intent” does not specify the contents of the proposed museum, the Presidio Trust has repeatedly and publicly endorsed the construction of a contemporary art museum to be donated by the Fishers. Given that the Notice of Intent is dated August 8, 2007, the same day as the news conference announcing the Fishers’ donation, I would venture to say that the Presidio has already decided what kind of museum will be constructed.

Regardless, let’s pretend that no decisions have been made. The NEPA (National Environment Protection Act) process, after all, exists to assist federal agencies in making well-informed decisions. Under NEPA the Presidio Trust must consider the potential environmental impacts of a range of alternatives, including “no action” and the “preferred alternative.” Potential alternatives could be:

o contemporary art museum at the southern boundary of the main parade ground
o contemporary art museum elsewhere in the presidio in existing structures
o historic museum at the southern boundary of the main parade ground
o historic museum in existing structures at the main post
o no action

Each alternative must receive equal or “comparable” analysis (40 CFR 1502.14) so perhaps the end result will recognize the benefits of having both a contemporary AND an historic museum in the Presidio. In these early stages, however, the Presidio is pitting historic versus contemporary. While there is virtually no money available for an historic museum, there is $16 million for a contemporary museum – ready to break ground in August 2008!

The Presidio is certainly large enough to have BOTH an historic and a contemporary museum. The real question hinges on siting: Do you insert a modern museum in the center of the most historic part of the Presidio, or do you put an historic museum in the core of its subject matter? A contemporary museum, totally unrelated to the Presidio, would be unaffected by its location elsewhere in the Presidio; but an historic museum outside of the heart of the historic landmark district would be sadly out of context. Freed from the constraints of the Main Post, the contemporary museum could have significantly more design options and could easily rid itself of parking, historic, and cumulative impact issues.

The proposed location of a newly constructed museum at the southern boundary of the Main Parade ground is rife with significant environmental issues: parking, historic resources, site lines, and transportation. Alone, any one of these issues could complicate the proposed museum, but when considered with the growing list of other Main Post projects (Main Parade Ground, Lodging, Doyle Drive, Building 100, etc.), the cumulative impacts are insurmountable. Project by project, the Presidio drifts away from its 2002 Presidio Trust Management Plan (PTMP) and examines each project individually, discounting the amalgamated effects. The PTMP is obsolete and must be revisited, complete with a NEPA review of the revised plan.

In summary, I support a contemporary museum in a different location, preferably in an existing building. I urge the Presidio to develop a fully integrated historic interpretive plan radiating from a museum in the Main Post. And I advise the Presidio Trust to prepare a new Management Plan to address the cumulative impacts of the myriad of proposed projects in and around the Main Post.

Thank you for the opportunity to comment on this proposed undertaking and I look forward to following its development

Another letter:

1. These comments are submitted in response to the announcement dated August 23 asking for comments concerning the scope of an E.I.S. for new construction of a 100,000 square foot museum at the Presidio.

2. The scoping must take place within the context of the Presidio of San Francisco being a National Historic Landmark District. It must comply with the standards of the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for the Treatment of Cultural Landscapes (National Park Service, 1996), related Department of the Interior publications, and NEPA.

3. The Trust is reminded of the Congressional Findings in the Trust Act:

The Congress finds that—
(1) the Presidio, located amidst the incomparable scenic splendor of the Golden Gate, is one of America’s great natural historic sites;
(2) the Presidio was the oldest continuously operating military post in the Nation dating from 1776, and was designated a National Historic Landmark in 1962;
(3) preservation of the cultural and historic integrity of the Presidio for public use recognizes its significant role in the history of the United States;

These basic principles have been echoed in numerous publications by the Presidio Trust, and the Trust has generally acted responsibly under financial constraints to carry out its strictly architectural preservation responsibilities. It has not, however, succeeded in responding to the Congressional directive intent in the phase, “FOR PUBLIC USE” in the context of cultural and historic integrity. The National Association of Public Administration report also highlighted the absence of normal functions for public and educational use of the portion of the Presidio under Trust management.

Therefore, the scope of the forthcoming E.I.S for a cultural institution must evaluate the effects of various proposals on the Trust’s compliance with meeting the Congressional intent for “public use” in the context of cultural and historic integrity.

4. The area proposed for primary consideration for a cultural Institution lies at the “head” of the Main Parade Ground, even though this area is excluded from the Main Parade Ground Environmental Assessment by designation of Sheridan Avenue as a boundary. This results in an irrational separation of the Main Parade Ground proposal and the museum proposal. One project flows into the other. Parking, public access, and cultural landscape integrity concerns are the same. Visitor experiences will be combined. The same preposterous segmentation and sequencing of environmental reviews applies to the lodging proposal currently under review by the Trust. The Presidio Trust is required avoid segmented and sequential reviews.

5. Recently completed and proposed projects in the Main Past of the Presidio and the magnitude of new construction in the proposed cultural institution, lodging, and Main Parade Ground proposals, as well as the long delayed realization of Building 102 as a visitor’s center, require review and updating of the Main Post District Concept and Guidance of the PTMP. This should fall out easily from a comprehensive E.I.S of Main Post in the context of the proposed major cultural institution, lodging plan, Main Parade plan, transit center, etc. Until this is done, it is inadequate to argue that detailed accommodation of the proposed public museum environmental review can be “tiered” directly from the Presidio Trust Management Plan. A “tiering” approach should be avoided in the scope of the new EIS.

6.The very few possible sites for major construction of a new cultural institution on the Presidio are precious. Each should be evaluated for its best use in terms of the public. A mistake in allocation one of these few locations for new construction cannot be undone. Alternative sites should be evaluated for various proposals for cultural institutions, including consideration of traffic, effect on cultural landscape integrity, and effectiveness in enhancing widespread public use by the general public, rather than a specific segment of the public, in the context of cultural and historical integrity, environmental education, or other public purposes normally served by a National Park.

The combination of major proposals concerning the Main Post District presently before the Trust may lead to the historic heart of the National Historic Landmark District becoming a truly public park offering pleasant visitor experiences and education relevant to the historic landmark to a large and diverse public. Unfortunately, these proposals could cumulatively make the Main Post into a preserve of unrelated private schools, foundations, and private museums, such as the Disney Family Museum and the proposed contemporary art collection, none of which have relevance to a National Park nor to a National Historic Landmark District. The scope of the forthcoming E.I.S. should be inclusive enough to respond to this challenge. Failure would mean the failure of Main Post as a National Park.

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