The Recent Past Preservation Network (RPPN) has issued a call for a revised environmental process for the Cyclorama Building at Gettysburg, Pennsylvania.
In August 2012, the National Park Service (NPS) issued an Environmental Assessment (EA) for the Final Disposition of the Gettysburg Cyclorama Building, a nationally significant structure designed by renowned architect Richard Neutra at the request of the Park Service as part of the influential Mission 66 Program. Preparation of the EA was mandated by the 2010 U.S. District Court ruling issued in response to a lawsuit
filed by RPPN and others against the NPS for failure to comply with National Environmental Policy Act (NEPA) obligations in planning for demolition of the building.
The NPS’ desire to demolish the Cyclorama has been a point of debate for more than 10 years, and the EA was to provide critical analysis of feasible alternatives to demolition prior to any implementing action and allow the public and interested parties to have a voice in the environmental review process. A public comment period accompanied the release of the EA; the closing date for comments was September 21, 2012.
In issuing its comments on the document in the form of a 15-page letter to staff of Gettysburg National Military Park and senior cultural resource staff at the NPS, RPPN notes that the EA is both arbitrary and capricious and fails to provide objective, critical analysis, thus systematically precluding meaningful public review and legally
defensible agency decision-making. Perhaps most notably, the EA fails to appropriately provide analysis of the Cyclorama within the multiple contexts for which it has been determined significant, eligible for listing in the National Register of Historic Places, and considered “exceptional” by the Keeper of the National Register and rationalizes a “no significant impact” finding despite regulatory guidance to the contrary.
In acknowledging the problems persistent in the EA, RPPN calls for the revision and recirculation of the EA for public review in order to fully comply with obligations under NEPA. Furthermore, RPPN has noted that the complexities of the project obligate the NPS to prepare an Environmental Impact Statement (EIS). For more information please visit: http://www.recentpast.org/cyclorama-ea-comment.
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