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Home arrow Working with Section 106 arrow Section 106 in Action arrow Archive of Prominent Section 106 Cases arrow Virginia: Norfolk Naval Station Hangars Master Plan

Virginia: Implementation of Norfolk Naval Station Hangars Master Plan

Agency: Department of the Navy

Criteria for ACHP Involvement:
  • Demolition of all of the historic hangars at the Norfolk Naval Air Station Historic District will impact a large portion of the district (Criterion 1).
  • This case has raised questions as to whether the selection processes for Military Construction projects include disincentives to preservation of historic buildings (Criterion 2).

Recent Developments

On May 15, 2001, ACHP signed a Memorandum of Agreement (MOA) for implementation of the Norfolk Naval Station hangar master plan. The MOA accepts the demolition of the facility’s nine historic hangars and provides for a number of mitigation measures. These include recordation of the buildings, development of a public interpretation program for the Naval Air Station Historic District, and development of a video on the founding of the base.

The Commander, Navy Region, Mid-Atlantic (CNRMA) also committed in the MOA to pursue Navy command approval to add the Norfolk Naval Shipyard to the list of properties covered by the Programmatic Agreement (PA) for management of historic Navy properties at Hampton Roads that was signed in 1999.


The Navy proposes to replace the nine historic hangars at Chambers Field, Norfolk Naval Station. Through six Military Construction (MILCON) projects phased over several years, the existing buildings would be replaced by six new buildings. CNRMA initiated Section 106 consultation in February 2000. Because of the interconnected nature of the phases of the overall plan, the Navy elected to address the plan’s components programmatically. Because of the extent of demolition proposed, ACHP entered the consultation.

The Norfolk Naval Air Station Historic District is one of several historic districts at Norfolk Naval Station. It is made up of five discontiguous parcels, the most important of which contain the World War II landplane and seaplane hangars of Chambers Field. Management of these and other historic properties at Norfolk Naval Station is subject to the PA for management of historic Navy properties at Hampton Roads that was signed in 1999. In accordance with that PA, the hangars have been identified as Category I buildings, the highest level of significance in the categorization system established by the PA. (For more information on the history and architecture of the Navy’s Hampton Roads facilities, visit

By November 2000, after 10 months of consultation, the Navy, ACHP, and the Virginia State Historic Preservation Office reached agreement on the language of a PA for the hangar demolition plan. Acknowledging the deficiencies of the hangars in meeting modern aircraft needs, it was agreed that six hangars would be demolished, and the remaining three would be studied for possible future reuse for various aircraft-related functions.

Then, about three weeks later, CNRMA reversed its position, indicating that it could not agree to future study of retaining any hangars since that would make the projects uncompetitive in the MILCON selection process. CNRMA also asserted that mission and program constraints made any reuse of the buildings untenable.

MILCON projects are developed and reviewed during a lengthy annual process that requires the branches of the military to anticipate their future construction needs and compete for congressionally allocated funds. There is not enough money to fund all construction requirements, so the Navy has established a scoring system for selecting which projects it will submit for congressional funding consideration.

In some circumstances, projects receive points for demolition, and CNRMA indicated that demolition of the Norfolk hangars would have to be included in the hangar master plan projects if they were to remain competitive. If this were the case, it would conflict with the stewardship mandates of Section 110 of the National Historic Preservation Act (NHPA) as well as the letter and spirit of Section 106 and ACHP’s implementing regulations, since it would make reconsideration of demolition effectively impossible.

Concerned that this case might highlight a serious systemic problem for the Navy’s compliance with Section 106, ACHP staff sought clarification on the MILCON process from the Deputy Assistant Secretary (Environment and Safety), the Navy’s Federal Preservation Officer. She reassured ACHP that there indeed is sufficient flexibility in the MILCON scoring system to permit adequate consideration of alternatives to demolition. Thereafter, consultation continued, focusing on CNRMA’s new conclusions regarding mission and program constraints on possible reuse of the hangars for other aviation uses.

Policy Highlights

While demolition of buildings is not required in order to obtain MILCON funding for Navy projects, there is a scoring preference given to demolition, and this can lead to misinterpretation, as apparently occurred in the case of the Norfolk hangar master plan. The Army and Air Force also have procedures for selecting which MILCON projects they will promote for limited congressional funding, so this issue may not be unique to the Navy.

In order to gauge the magnitude of the problem, ACHP has requested the Secretary of Defense, in his position as an observer on ACHP, to report on how the military services’ MILCON selection processes work, with an evaluation of their incentives and disincentives for preservation and their overall compatibility with the policies of NHPA.

Staff contact: Druscilla Null

Updated June 6, 2002

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