Return to Case Digest Archives
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)

Virginia: Reservoir
(King William County)

Return to Archive of Prominent Section 106 Cases

Archive of Prominent Section 106 Cases:
July 1999

Puerto Rico: Rehabilitation of Defensive Walls (San Juan National Historic Site)

Agency: National Park Service

Criteria for Council Involvement:

  • This undertaking could adversely affect the fortification walls of San Juan National Historic Site, a World Heritage Site of international importance (Criterion 1).
  • There have been procedural disputes among the consulting parties that the Council has helped to resolve (Criterion 3).

Recent Developments

In June, the National Park Service (NPS) and the Puerto Rico State Historic Preservation Office (SHPO), through the U.S. National Committee of the International Council on Monuments and Sites (US/ICOMOS), convened an international team of conservation specialists to analyze the range of treatment proposals under consideration by NPS for maintenance and rehabilitation of the fortification walls at San Juan National Historic Site. Invited to participate as an observer, the Council designated staff member Martha Catlin as its representative at the meetings of the expert committee. The meetings included onsite inspections, presentations by both NPS and the SHPO, review of documentary materials, dialogue with interested parties, and deliberations among the panelists.

At the culmination of the sessions, the committee presented a report of their findings and recommendations to NPS and the SHPO. The document recommended specific methods and techniques to implement a program of minimal intervention, which, while intensive, nonetheless consist only of “those actions which will protect existing fabric and slow down decay.” The recommended approach was deemed by the group to be the most respectful of the multiplicity of values associated with the site and the one that most effectively allows for the preservation of extant historic fabric.

The report was accompanied by a resolution by US/ICOMOS recommending acceptance of the committee’s offer to continue its participation through appropriate follow-up actions. Consistent with the January 1998 agreement wherein NPS and the SHPO outlined steps to be taken to address the park’s Section 106 responsibilities for this project, the Council will now work further with NPS, the Puerto Rico SHPO and the interested public to develop a Programmatic Agreement for implementation of the recommendations contained in the report.


In 1997, NPS began work on a project to rehabilitate the historic defensive walls surrounding the San Juan National Historic Site. In addition to being a unit of the National Park system, the historic district encompassed by the walls is listed on the National Register and, along with the adjacent fortress La Fortaleza, was designated a World Heritage Site in 1983. Upon completion of repairs and stabilization treatments, NPS proposed to cover the walls with a mixture of stucco and mortar. The Puerto Rico SHPO objected to NPS's determination of no adverse effect for this aspect of the project, arguing that the stucco treatment would jeopardize the walls' structural integrity by trapping moisture. In addition, the SHPO held that stucco would compromise the walls' visual integrity by covering and destroying the surface, which the SHPO considered an important character-defining feature because of its patina of age.

After the stuccoing project was initiated on the north wall, the Puerto Rico SHPO asked the Council to investigate the status of NPS compliance with Section 106. The questions this raised, coupled with evident physical problems with the stucco application, led NPS and the SHPO to enter into an agreement in January 1998 which detailed a plan for addressing both the disputed north wall project and the remaining sections of the historic wall yet to be rehabilitated. The Council responded with support for the proposed conceptual approach, which included the Council as a full participant and allowed technical and philosophical issues to be explored by an interdisciplinary team of experts.

Policy Highlights

The technical problems associated with rehabilitating the historic walls of San Juan require that the best principles of conservation science be applied. However, the significance of the property and its importance to the public also require that expert advice on treatment decisions be informed by public dialogue. The convening of an interdisciplinary team to provide expertise within the context of the public Section 106 review is an innovative approach certainly warranted by both the scope of the problem and the importance of the resource.

Staff contact: Martha Catlin

Return to top of page

ACHP home page Working with Section 106

We welcome your feedback