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Archive of Prominent Section 106 Cases:
January 1999

Arizona: Construction of
Holbrook Interchange
(Woodruff Butte)

Arizona: Demolition of North Rim Inn Cabins (Grand Canyon National Park)

California: Closure and Disposal of Marine Corps Air Station (Tustin)

California: Construction of U.S. Courthouse (San Diego)

Hawaii: Ewa Villages Redevelopment (Honolulu)

Massachusetts: AHEPA-Daughters of Penelope Elderly Housing Project (Peabody)

Pennsylvania: Closure and Disposal of Philadelphia Naval Hospital

Virginia: Woodrow Wilson Memorial Bridge Replacement (Alexandria, VA, and P.G. County, MD)

West Virginia: Corridor H Highway Construction

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Archive of Prominent Section 106 Cases:
January 1999

California: Closure and Disposal of Marine Corps Air Station (Tustin)

(Click here for the latest update on this case)


The Marine Corps Air Station (MCAS) Tustin was identified for closure in the Defense Base Realignment and Closure Act of 1990. This installation is well-known for two wooden dirigible hangars built by the Navy during World War II to house naval patrol blimps. Listed on the National Register of Historic Places since 1974, the hangars are recognized as the largest wooden buildings in the world (along with contemporary, identical hangars at Moffett Field in the San Francisco bay area). Tustin Blimp Hangar

The Tustin, California, blimp hangars are some of the largest wooden buildings in the world, even having their own interior microclimate.

The proposed local reuse plan recommends redevelopment of a portion of the installation as a regional park, which would include Hangar 1. However, the proposed new owner, Orange County, opposes the creation of a historic district and the imposition of any restrictions that would hamper the development of a park master plan. Additionally, the County proposes to demolish Hangar No. 2 and has been unwilling to implement a marketing plan that might identify interest in the property and feasible, economically viable reuses.

Section 106 consultation was initiated in the Spring of 1997. Both the California State Historic Preservation Officer (SHPO) and the Council have voiced concern regarding the fate of the hangars, but active negotiations have been suspended by the Marines for the last year. However, an unprecedented action by the State of California has refocused attention on the case.

In September 1998, the State passed a law (introduced by an Orange County senator) that requires the California SHPO to agree to the City of Tustin assuming the SHPO's prescribed duties within the survey area of the MCAS Tustin redevelopment project. Shortly following the enactment of this legislation, the California Preservation Foundation, the statewide, non-profit preservation organization, requested the Council's opinion on the legal effect of this bill on the SHPO's responsibilities under the National Historic Preservation Act.

Policy Highlights

In response, the Council's Office of General Counsel issued a legal opinion concluding that the State of California may not unilaterally delegate the SHPO's role and responsibilities under Section 106. Under the Council's regulations, a Certified Local Government such as the City of Tustin may assume the SHPO's Section 106 responsibilities only if agreed to by the SHPO, the local government, and the Council.

The effect of the State law on Section 106 review of the Tustin reuse project is to eliminate State participation while not changing the City of Tustin's role as, at most, a consulting or interested party. Other broad and inconsistent provisions of the bill have been determined to be ambiguous, and raise issues that may undermine its effectiveness.


At this point, the Council is awaiting reopening of consultation by the Marine Corps.

Staff contact: Lee Keatinge

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