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Archive of Prominent Section 106 Cases:
March 2000


Criteria for

Grand Canyon

California: Gold Mine
(Imperial County)

California: Marine
Corps Air Station

Florida: Rowland Subdivision

Georgia: Fort Benning/City of Columbus

Pearl Harbor

Kansas: Eisenhower Medical Center

New Jersey: Textile Printing Site


Virginia-Maryland: Woodrow Wilson Bridge

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Archive of Prominent Section 106 Cases:
March 2000

California: Closure and Disposal of
Marine Corps Air Station, Tustin

Agency: U.S. 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

A Memorandum of Agreement (MOA) for the disposal and reuse of the Marine Corps Air Station Tustin was executed by the Council on December 13, 1999. The MOA provides standards for marketing the station’s historic blimp hangars and requires that they be transferred with a preservation covenant if an economically viable adaptive use is identified through the marketing.

Tustin Blimp Hangar

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

If either hangar will be transferred without a preservation covenant, the recipient will be required to document the hangar complex through preparation of a written history, an interpretive exhibit, and a professional quality documentary video. The State Historic Preservation Officer (SHPO) was a signatory to the MOA despite earlier questions regarding the status of the SHPO that resulted from State legislation.


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 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.

However, following productive meetings between the California SHPO, State officials, and the Council, the SHPO rejoined consultation when it was reinitiated in 1999 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 later became moot, since the Council’s 1999 regulations no longer provide for the delegation of SHPO responsibilities to CLGs.

Staff contact: Lee Keatinge

October 1999 report on this case

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