Call for public comments

The latest version of the Army's draft Programmatic Agreement (PA) is available on the Army's Section 106 website, at www.monroe.army.mil/monroe/sites/Section106/Section106.aspx (click on "Programmatic Agreement"). This version, dated June 4, 2008, was published after the recent round of public meetings in Hampton, Richmond and Washington, D.C. and, significantly, after review by senior Army officials and the Virginia Attorney General's office. The PA is envisioned as an overlay over reuse plans for Fort Monroe, assuring protection of historic resources, both before and after the Army's departure.

The PA is now 65 pages in length, including appendices, and there is a lot to say for it. Responding to previous public comments, it is clear in requiring all 570 acres be treated as a whole and that any reuse proposal take into account its effect on the entire National Historic Landmark (which the Army seeks to expand, to include all 570 acres). The PA requires conduct of professional viewshed and cultural landscape studies by the Army, and recognition of their results in reuse plan. Design standards for historic and any new construction will be developed and shall be complied with in redevelopment. And Virginia would establish a Fort Monroe Historic Preservation Officer to oversee historic resources at Fort Monroe following departure of the Army.

Still, there remain significant shortcomings in this PA from prior drafts, despite overwhelming public comment on them. And some recent PA changes applicable to the review of specific reuse plans that may have an adverse effect on historic properties, or lead to significant amendment or even termination of the PA down the road, raise new concerns. We commend to you comments raising the following; comments can be sent by e-mail to monr.106public@us.army.mil :

1. Modify the PA to preclude sale of any Fort Monroe land to a private individual or business, thus maintaining Old Point Comfort's historic public character (protecting this character is in fact mandated by Virginia law applicable to reuse of Fort Monroe). Rely on leases for historic properties to be reused by private parties and for any limited parcels of land to be developed by private parties. The current version of the PA unfortunately allows private sales.

2. Modify the PA to eliminate any implication that it approves developing Fort Monroe for development's sake alone (as opposed to generating funds needed to sustain Fort Monroe). At one point, the current version of the PA refers with approval to Virginia using Fort Monroe to generate profits, a position inconsistent with both protecting the historic resource and the public’s clearly expressed desires.

3. Modify the PA to bar or severely limit new development on Zone B, the Wherry Quarter, the middle portion of the property just northeast of stone fort (now occupied by Wherry Housing, bowling alley and other post-WWII construction). The current PA allows extensive new construction here, thus harming significantly the character of the Landmark and reducing its potential for National Park Service participation in the future.

4. Review carefully and strengthen significantly the provisions governing future review of specific reuse projects, and allowing amendments to and termination of the PA. Under recent redraft of PA, Virginia authorities would have, after the Army's departure, near carte blanche authority to interpret, amend or even scrap the PA, with a yet undetermined level of public input.