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Archive of Prominent Section 106 Cases:
July 1999


California: Marine Corps Air Station (Tustin)

California: U.S. Courthouse (San Diego)

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Florida: Stiltsville Com-
plex (Biscayne Bay)

Kansas: South
Lawrence Trafficway

Louisiana: Industrial Canal Lock (New Orleans)

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Ohio: Sand & Gravel Mine (Buffington Island)

Ohio: Cleveland Bulk Terminal

Pennsylvania: Philadelphia Naval Hospital

Pennsylvania: Visitor Center & Museum Complex (Gettsyburg)

Puerto Rico: Defensive Walls (San Juan)

Texas: USS Cabot/ Dedalo (Brownsville)

Virginia: Reservoir
(King William County)

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Archive of Prominent Section 106 Cases:
July 1999

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

(Latest update)

Agency: Navy

Criteria for Council Involvement:

  • This undertaking may result in transfer without covenants or demolition of the Tustin dirigible hangars, a rare property type and some of the largest wooden buildings in the world (Criterion 1).
  • There are unique procedural problems, since the role of the State Historic Preservation Officer has been impacted by State legislation (Criterion 3).

Recent Developments

Consultation under Section 106 for disposal of the Tustin dirigible hangars in Orange County has been reinitiated by the Navy, acting on the behalf of the Marine Corps. The Navy has completed its initial public outreach efforts, conducted a meeting with the stakeholders and interested parties, and circulated a preliminary draft of a Memorandum of Agreement (MOA) for comment.

Tustin Blimp Hangar

The Tustin, California, blimp hangar is one of the largest wooden buildings in the world, even having its own interior microclimate.

In response to the State legislation aimed at removing the State Historic Preservation Officer (SHPO) from this Section 106 consultation, the California SHPO met with State officials, including the State Senator, Ross Johnson, who introduced the legislation. As a result, the SHPO has rejoined consultation. The Navy’s goal is to conclude the Section 106 review by early October.


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. 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. The city of Tustin, acting as the Local Reuse Authority, opposes the transfer of the property with preservation restrictions and has been unwilling to implement a marketing plan that might identify interest in Hangar 2 and feasible, economically viable reuses. Additionally, the Navy will be required to remediate contaminated ground water underneath Hangar 2, which will affect the timing of the marketing effort and may limit the proposed reuses of the property.

The Marine Corps initiated Section 106 consultation in the spring of 1997, and both the California SHPO and the Council voiced concerns at that time regarding the fate of the hangars. During 1998, the Marines suspended discussions, 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. Shortly following the passage of this legislation, the California Preservation Foundation, the statewide, nonprofit 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 November 1998, 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 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 effect of the law on Section 106 review for Tustin project was to eliminate State participation while not changing the City of Tustin's role as, at most, a consulting or interested party. 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

January 1999 report on this case

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