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Archive of Prominent Section 106 Cases:
July 1999


California: Marine Corps Air Station (Tustin)

California: U.S. Courthouse (San Diego)

California: Gold Mine (Imperial County)

Florida: Stiltsville Com-
plex (Biscayne Bay)

Kansas: South
Lawrence Trafficway

Louisiana: Industrial Canal Lock (New Orleans)

New Jersey: Congress Hall Hotel (Cape May)

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)

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(King William County)

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Archive of Prominent Section 106 Cases:
July 1999

Pennsylvania: Closure and Disposal of the Philadelphia Naval Hospital

(Latest update)

Agency: Navy

Criteria for Council Involvement:

  • This undertaking may 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 April, the Secretary of the Navy terminated further consultation on the disposal of the Philadelphia Naval Hospital. In order to formulate the Councilís final advisory comments, Chairman Slater appointed a panel of Council members, representing the General Services Administration, the National Trust for Historic Preservation, and the Architect of the Capitol, to review the case. Council staff and representatives of the National Trust then visited the site and met with the consulting parties, interested citizens, and preservation groups.

On July 9, the Councilís comments were transmitted to the Secretary. The Council concluded that efforts by the Navy and the City to explore the feasibility of adaptive reuse have been 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 City issuance of a Request for Proposals (RFP) for redevelopment that would preserve the complexís 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, which set the stage for termination of consultation.


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 been 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 has been described in a survey of Philadelphia architecture as "one of the finest Art Deco buildings in the city."

The City of Philadelphia has expressed interest in obtaining the parcel and has prepared a proposed reuse plan for the property. This plan, which calls 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 the original 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. Recently, however, the city has proposed to rezone part of the property, which is adjacent to Veterans Stadium, to permit development of a practice facility for the Philadelphia Eagles football team.

The Council and the Navy consulted to determine the best way to ascertain the potential for preserving the most significant parts of the Philadelphia Naval Hospital complex. The Council's position was that marketing would be the best tool for gauging redevelopment potential of the site. Therefore, the Council recommended that the Navy either offer the property to the city to market with a preservation covenant, or, if the city was unwilling to do so, that the Navy undertake marketing as part of a public sale. This approach would, however, run counter to the city's preferred plan for the site.

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—years 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

January 1999 report on this case

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