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Archive of Prominent Section 106 Cases:
October 1999


Criteria for

California: Marine Corps Air Station (Tustin)

California: U.S. Courthouse (San Diego)

California: Gold Mine (Imperial County)

California: Geothermal Developments (Modoc
& Klamath National Forests)

Florida: Rowland Subdivision (Okeechobee)

Kansas: South
Lawrence Trafficway

Louisiana: Industrial Canal Lock (New Orleans)

Minnesota-Wisconsin: Stillwater Lift Bridge

New Jersey: Congress Hall Hotel (Cape May)

Ohio: Cleveland Bulk Terminal

Pennsylvania: Philadelphia Naval Hospital

Texas: USS Cabot/ Dedalo (Brownsville)

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Archive of Prominent Section 106 Cases:
October 1999

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

(Latest update)

Agency: Navy

Criteria for Council Involvement:

  • This undertaking could result in transfer or demolition of the Tustin dirigible hangars, a rare property type and some of the largest wooden buildings in the world (Criterion 1).
  • There have been unique procedural problems, since the role of the State Historic Preservation Officer was impacted by State legislation (Criterion 3).

Recent Developments

The Navy, the California State Historic Preservation Officer (SHPO), the National Park Service, the Council, the City of Tustin, and the County of Orange have reviewed several drafts of a Memorandum of Agreement (MOA) for the disposal and reuse of the Marine Corps Air Station, Tustin.

Tustin Blimp Hangar

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

In particular, the parties have worked to develop guidelines for a marketing plan. The goal is to broadly advertise the availability of the two hangars yet encourage only serious offers from developers who can make these unique properties economically viable. If such developers can be located, the structures will be transferred with preservation covenants. Final discussions are underway, and it is anticipated that the MOA will be executed in the near future.


Marine Corps Air Station Tustin was identified for closure in the Defense Base Realignment and Closure Act of 1990. The installation is known for its two wooden dirigible hangars built by the Navy during World War II to house naval patrol blimps. Listed in the National Register of Historic Places since 1974, the hangars are recognized as among the largest wooden buildings in the world.

The proposed local reuse plan would redevelop a portion of the installation as a regional park to include Hangar 1. Initially, however, the proposed new owner, Orange County, opposed accepting the property with any preservation restrictions that might hamper the development of a park master plan. The City of Tustin, acting as the Local Reuse Authority, also initially opposed the transfer of the property with preservation restrictions and did not want to implement a marketing plan to identify interest in Hangar 2.

The Marine Corps initiated Section 106 consultation in the spring of 1997, and at that time both the California SHPO and the Council voiced concerns about the fate of the hangars. The Marine Corps suspended discussions during 1998, but an unprecedented action by the California legislature kept the Council’s attention focused on the project.

A State law was enacted to require the California SHPO to agree to the City of Tustin assuming the SHPO’s prescribed duties within the survey area of the redevelopment project. Following productive meetings between the California SHPO and State officials, the SHPO rejoined consultation when it was reinitiated this year by the Navy, acting on behalf of the Marine Corps.

Policy Highlights

In November 1998, at the request of the California Preservation Foundation (the statewide, nonprofit preservation organization), the Council’s Office of General Counsel issued a legal opinion concluding that the State of California could not unilaterally delegate the SHPO’s role and responsibilities under Section 106. Under the Council’s 1986 regulations, a Certified Local Government (CLG) such as the City of Tustin could assume the SHPO’s Section 106 responsibilities only if the SHPO, the local government, and the Council agreed to permit it. The issue now appears to be moot, since the Council’s 1999 regulations no longer provide for the delegation of SHPO responsibilities to CLGs.

Staff contact: Lee Keatinge

July 1999 report on this case

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