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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

Pennsylvania: Closure and Disposal of the Philadelphia Naval Hospital

(Latest update)

Agency: Navy

Criteria for Council Involvement:

  • This undertaking will result in the demolition of one of the finest Art Deco buildings in the City of Philadelphia (Criterion 1).
  • The undertaking also raises questions regarding published Navy policy on Section 106 compliance for base closures (Criterion 2).

Recent Developments

In August 1999, the Secretary of the Navy responded to the Council’s advisory comments on the disposal of the Philadelphia Naval Hospital. Regrettably, the Secretary elected to accept only one of the Council’s three recommendations. The property will be documented before transfer and previously salvaged items will be made available for reuse on the site.

Conveyance of the property will not, however, be conditioned upon issuance of a Request for Proposals (RFP) by the City of Philadelphia for redevelopment that would preserve the Art Deco hospital complex. Neither will the Navy revise its policy on Section 106 compliance for base closures.


Under the Base Realignment and Closure Act of 1988, the Philadelphia Naval Hospital was slated for closure and disposal. All functions were relocated from the complex in 1993 and, since that date, the buildings have stood vacant, overseen by a small security and maintenance staff.

The complex’s earliest buildings date from 1933-1936. The most prominent is Building 1, a 15-story, Art Deco-style tower faced with yellow brick and brown terra cotta that a survey of Philadelphia architecture describes as “one of the finest Art Deco buildings in the city.”

The City of Philadelphia has expressed interest in obtaining the parcel and prepared a proposed reuse plan for the property. This plan, which called for demolition of all structures on the site, was predicated on a belief that the historic buildings could not be economically reused and was developed before the property was formally determined eligible for the National Register. Under this plan, the property would be redeveloped with market-rate townhouses, a nursing home and assisted living facility, a park, and a 1,100-space parking lot.

The city proposed recently to rezone part of the property adjacent to Veterans Stadium to permit development of a practice facility for the Philadelphia Eagles football team.

Despite extensive consultation, the Navy and the Council could not reach agreement regarding ways to avoid or mitigate impacts to the hospital complex. In April, the Secretary of the Navy terminated further consultation and requested final Council comments.

In order to formulate those comments, Chairman Slater appointed a panel of Council members to review the case: the General Services Administration, the National Trust for Historic Preservation, and the Architect of the Capitol. Council staff and representatives of the National Trust then visited the site and met with the consulting parties, interested citizens, and preservation groups.

In July, the Council’s comments were transmitted to the Secretary. The Council concluded that efforts by the Navy and the city to explore the feasibility of adaptive reuse were insufficient, notably due to the lack of any marketing of the property. The Council therefore recommended that the Navy reexamine its alternatives, including the previously rejected option of marketing for public sale.

At a minimum, the Council recommended conditioning conveyance to the City upon issuance of a RFP for redevelopment that would preserve the complex’s 1930s buildings. Although the final decision on reuse would rest with the City, issuing an RFP would offer one last chance for this important resource. The Council also urged the Navy to reconsider Navy Policy Memorandum #98-07, the policy which set the stage for termination of consultation.

Policy Highlights

The Navy recently issued Navy Policy Memorandum #98-07, which establishes principles to guide the Navy in complying with Section 106 for base closures. Although the policy emphasizes early consideration of historic preservation, it was issued only last year—well after the last round of base closures.

Therefore, it may not be effective in influencing local planning. This is a problem, since the same memorandum also establishes Navy policy against public sale of historic properties with preservation covenants when such sale would run counter to local reuse plans. This case raises questions as to whether limiting the potential use of public sales inappropriately constricts the Navy’s ability to fully take into account the effect of disposal on important historic properties.

Staff contact: Druscilla Null

July 1999 report on this case

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