CNPSR Testimony: H.R. 6305: To clarify the authorization for the use of properties within "Golden Gate National Parks"

NOTE: CNPSR submitted the following testimony for the record in relation to a recent hearing on this proposed legislation.

Testimony On H.R. 6305:
To clarify the authorization for the use of certain National Park Service properties within Golden Gate National Parks and San Francisco Maritime National Historic Park, and for other purposes.

Prepared in Relation to Legislative Hearing held by the Subcommittee on National Parks, Forests & Public Lands July 15, 2008.

The Coalition of National Park Service Retirees is privileged to submit the following comments on H.R. 6305 and appreciate the Committee’s willingness to accept our testimony.

The Coalition was formed in 2003 when it sent a letter to Secretary of the Interior Gale Norton signed by 20 NPS retirees voicing their concerns over the actions being taken that were detrimental to the National Park Service. Since then the numbers have grown to 660 members, many of whom were senior managers in the NPS. The Coalition is working to support the mission of the National Park System and the employees who carry it out.

Section 1. Golden Gate National Recreation Area and San Francisco Maritime National Historical Park Technical Corrections.

(a) Concession Contracting:
Inasmuch as that the Cliff House Properties are already the property of the National Park Service, the use of proceeds from the properties should be returned to the Treasury of the United States and not be used to generate money for use locally. The Fort Mason Agreement referred to in the Bill addressed only the military properties within the Presidio and should not be used as a justification for increasing the income of the Presidio Trust.

(b) San Francisco Maritime National Park:

(1) LEASING –
We have no objection to this provision.
(2) FEES –
We have no objection to this provision recognizing that the maintenance of historic vessels, equipment, piers, etc. is very expensive when compared to properties located on land.

(c) Conforming Amendment:

(1) MAP; BOUNDARY –
We have no objection to this provision.
(2) FEES OR ADMISSION CHARGES –
Under the provision of Section 4(e) of P.L. 92-589, the Secretary of the Interior already has authorization to establish “reasonable charges for public transportation and for admission to the sailing vessel Balclutha and other historic vessels of the National Maritime Museum.” If the purpose of this provision is to provide for the charging of admissions at the San Francisco Maritime Museum, we have no objection.

Sec. 2. GOLDEN GATE NATIONAL PARKS

(a) Name Change –
The Coalition is adamantly opposed to creating a new designation within the National Park System. Regardless of what is presented in (b) (2) CLARIFICATION the term “National Parks” is a new category. Because of the urban nature and multitude of uses not usually found in national parks, Golden Gate National Recreation Area was established as a recreation area.

Classification of areas within the National Park System have been generally based on the criteria found in the NPS Management Guidelines. Natural areas within the System which are designated “national parks” because of the large complex of resource areas. If the justification for changing the name of Golden Gate NRA is because of it great natural beauty, the Big Sur area is more attractive and should be considered before Golden Gate NRA. National Recreation Areas began around the shorelines of US Government reservoirs and continued until 1972 when military and other federal lands became surplus. According the Dwight F. Rettie, a historian of the National Park System, “…they [the NRA’s] were an ingenious invention and a remarkable departure from the historic pattern of rural sites serving a clientele who often traveled long distances to be there. Their ingenuity was based on recycling military bases, buildings, and waterfronts for public recreation, conservation and historic preservation.” Also, within national parks, all consumptive uses are forbidden which is not the case in Golden Gate NRA.

Although Muir Woods National Monument and John Muir National Historic Site are under the administrative support of Golden Gate NRA, they need to maintain their separate identities as a National Monument and National Historic Site.

SEC. 3. PRESIDIO TRUST TECHNICAL CORRECTIONS

(a) Public Information and Interpretation –
We are strongly opposed to the changes which would result in an independent interpretive service to be provided by the Presidio Trust. The responsibility for providing public interpretive services, visitor orientation and educational programs should reside with the National Park Service. Any change would be a further step in the privatization of the Presidio. We do not agree with our colleagues in the NPCA who advocate two independent interpretive systems, but we do agree that there is a need for the National Park Service to complete the Interpretive Plan for Golden Gate NRA.

(b) Transfer, Board of Directors –
The Coalition feels that the National Park Service should decide where the Visitor Center should be located on the Presidio upon completion of the Interpretive Plan. The idea of naming the Visitor Center after former Director William Penn Mott should be held in abeyance until the completion of the Interpretive Plan. We feel that Director Mott’s interest in and support for Golden Gate NRA should be recognized within the park. The idea of joint management of the Visitor Center between all interested parties such as the National Park Service, the Presidio Trust and the Presidio Historical Association would provide an interpretive voice to all parties involved in the future of the Presidio.

(c) Duties and Authorities of the Trust –
We feel that the re-writing of the existing law places too much emphasis on the Presidio Trust in the management of Presidio which is part of Golden Gate NRA. An example of the problems with an independent Trust is best seen in the California State Historic Preservation Officer’s letter stating that the Trust procedures in presenting the case for the art museum adjacent to the historic Main Parade Ground were faulty and that his office was no longer in a cooperative frame of mind. The National Park Service commented that such an art museum proposal would “threaten the National Historic Landmark Designation” because of the impact on the historic Main Parade Ground. The Presidio Trust has already proposed construction of the 100,000 square foot art museum, a hotel of some 95,000 square feet, expansion of the theater [Bldg. 99] three times over its current footprint not to mention the demolition of some existing historic structures. These proposals would affect some 145,000 square feet of the historic Main Post Area.

The Coalition understands that the original purpose of the Presidio Trust was to manage the real estate of the Presidio and not a structure to compete with the National Park Service. It may be time to re-examine the self-sufficiency clause which directed the Presidio Trust to be self-sufficient by 2013. This demand more showing a profit for the Presidio influences all the decisions made by the Presidio Trust. In the case of the Presidio, we feel that historic preservation trumps economics. The public good and historic preservation should be the guiding principles of management of this outstanding historic resource.

(d) Limitations on Funding –
It is not the function of the Presidio Trust to provide law enforcement activities and services. The present structure of law enforcement is adequate and does not complicate a delicate law enforcement situation.

(e) Government Accountability Office Study -
The Coalition is strongly opposed to any reduction of responsibility of the Government Accountability Office. The use of the term “Government Accountability” in place of the GAO is unfounded and unnecessary.

SEC.108 FORT SCOTT ADVISORY TASK FORCE

We recognize the need to examine Fort Scott regarding the preservation and use of Fort Scott, but feel the creation of an advisory task force in unnecessary. The Park Superintendent has it within his authority to create an advisory task force to determine the future of Fort Scott. Nothing should be done at Fort Scott until the Interpretive Plan is completed.

GENERAL COMMENTS:
The Coalition feels that the original Congressional Finding adequately describes the purpose and use of Golden Gate National Recreation Area.
(1) the Presidio, located amidst the incomparable scenic splendor of the Golden Gate, is one of America’s great natural and historic sites;
(2) the Presidio is the oldest continuously operated military post in the Nation dating from 1776, and was designated a National Historic Landmark in 1962;
(3) preservation of the cultural and historic integrity [emphasis added] of the Presidio for public use recognizes its significant role in the history of the United States;
(4) the Presidio, in its entirety, is part of the Golden Gate National Recreation Area, in accordance with Public Law 92-589;
(5) as part of the Golden Gate National Recreation Area, the Presidio’s significant natural, historic, scenic, cultural, and recreational resources must be managed in a manner which is consistent with sound principles of land use planning and management, and which protects the Presidio from development and uses which would destroy [emphasis added] the scenic beauty and historic and natural character of the area and cultural resources and recreational resources;
(6) removal and/or replacement of some structures within the Presidio must be considered as a management option in the administration of the Presidio; and
(7) the Presidio will be managed through an innovative public/private partnership that minimizes cost to the United States Treasury and makes efficient use of private sector resource.

These guiding principles should provide the basis for any decision made as to the preservation, use and management of one of America’s treasures.