CPANP Letterhead

 

July 8, 2021

The Honorable Joe Manchin, Chairman
Committee on Energy and Natural Resources
U.S. Senate,
304 Dirksen Senate Office Building
Washington, DC 20510
The Honorable John Barrasso, Ranking Member
Committee on Energy and Natural Resources
U.S. Senate,
304 Dirksen Senate Office Building
Washington, DC 20510

Subject: Opposition to S. 1812 – A bill to expand Lincoln Home National Historic Site

Dear Chairman Manchin and Ranking Member Barrasso:

I am writing on behalf of over 1,900 members of the Coalition to Protect America’s National Parks (Coalition), whose membership is comprised of retired, former, or current National Park Service (NPS) employees. As a group we collectively represent over 40,000 years of experience managing and protecting America’s most precious and important natural and cultural resources. Among our members are former NPS directors, regional directors, superintendents, resource specialists, rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.

The Coalition is very concerned about the Lincoln Home National Historic Site Boundary Modification Act (S. 1812). The legislation proposes to expand the boundary of the Lincoln Home National Historic Site (Lincoln Home or NHS) in Springfield, Illinois, to incorporate a donated reconstruction of “Lincoln’s Springfield cottage”, as well as the historic Elijah Iles House.

As background, “[t]he Lincoln Home was the first and only home Abraham Lincoln owned and still stands today, with much of the original structure, walls, and foundations remaining… Its growth and expansion mirror the growth of the Lincoln family from a young couple with a baby, to a presidential family bound for the White House, as well as Lincoln’s growth from a young lawyer of humble origin to the highest position in the United States.”1https://www.nps.gov/liho/learn/historyculture/the-lincoln-home.htm

As proposed, the Abraham Lincoln Association, a friends group incorporated to provide financial support to Lincoln sites and research, would acquire a vacant lot near Lincoln Home NHS, then construct and donate a replica of the “cottage” as it may have appeared before it was expanded by the Lincolns multiple times. Please understand that while the Lincolns lived in the home from 1844-1861, the original “cottage” only accounted for two years of that occupancy.  It had been constructed in 1839 for the Reverend Charles Dresser; then purchased and moved into by the Lincoln family in 1844. The Lincolns subsequently made multiple additions and changes to the structure in 1846, 1849-1850, 1853, 1855, 1856, and then again in1859.2https://www.nps.gov/liho/learn/historyculture/homechronology.htm After the Lincolns moved to the White House, the home remained in the Lincoln family; however, it was occupied by a series of tenants from 1861 until the home was donated to the State of Illinois in 1887.

Given that historical context, the primary effect of the legislation would be to expand the boundary of Lincoln Home National Historic Site to incorporate a replica structure of a cottage that the Lincolns lived in for only two years; and that replica would be located at a site that is not associated with the original Lincoln home. The legislation would also incorporate a nearby historic structure, the Elijah Iles House, into the NHS that is otherwise unaffiliated with the Lincolns.

As a result, the legislation raises serious concerns about the NPS accepting properties into the National Park System under conditions that do not conform to the agency’s cultural resource regulations and policies; and that do not meet the goals of the national historic site’s general management plan (GMP).

While the proposal may be well-intended, we believe these properties would not be appropriate additions to Lincoln Home NHS for the following reasons:

1. The proposed boundary expansion and the plan to reconstruct a Lincoln Home from an earlier period do not conform to the Secretary of the Interior’s Standards for the Treatment of Historic Properties and NPS Management Policies3https://www.nps.gov/tps/standards.htm.

  • The Lincoln Home National Historic Site in Springfield IL was established in 1971 for the purpose as stated in its enabling legislation “to preserve and interpret for the benefit of present and future generations the home of Abraham Lincoln in Springfield, Illinois.” Pub. L. 92–127, Aug. 18, 1971, 85 Stat. 347. It also interprets a four-block area with the original Lincoln Home as the centerpiece of the site. Today, the Lincoln Home is fully interpreted to the period of 1844 -1861, including changes made by the Lincoln family to the property.The National Historic Preservation Act (1966) authorized the promulgation of regulations on the treatment of historic resources. The Secre­tary of the Interior’s Standards for the Treatment of Historic Properties were developed by the National Park Service in 1978 and were later codified in the Federal Register (36 CFR 68.3) in 1995. At the same time, guidelines were also published to assist in their implementation of the standards. These guidelines were updated in 2017. These standards and guidelines are a critical part of the framework of the national preservation program and are widely used at the federal, state, and local levels across the nation.The standards specifically speak to the issue of “reconstruction”. It is defined as “the act or process of depicting, by means of new construction, the form, features, and detailing of a non-surviving site, landscape, building, structure, or object for the purpose of replicating its appearance at a specific period of time and in its historic location.” The standards do not encourage this practice and state that reconstruction should be undertaken only if it can be done with a minimum of conjecture and, most relevant to this matter at hand, if the reconstruction “…is essential to the public’s understanding of the property.”  36 CFR 68.3 (d) (1).More specifically, NPS Management Policies 20064https://www.nps.gov/policy/mp/policies.html limits “reconstruction of missing historic structures” in Section 5.3.5.4.4, which states: “No matter how well conceived or executed, reconstructions are contemporary interpretations of the past rather than authentic survivals from it. The National Park Service will not reconstruct a missing structure unless (emphasis added):
  • there is no alternative that would accomplish the park’s interpretive mission;
  • sufficient data exist to enable its accurate reconstruction based on the duplication of historic features substantiated by documentary or physical evidence rather than on conjectural designs or features from other structures;
  • reconstruction will occur in the original location;
  • the disturbance or loss of significant archeological resources is minimized and mitigated by data recovery; and
  • reconstruction is approved by the Director.

It behooves the NPS, as the nation’s leading historic preservation agency, to adhere to its own best management practices. In this case, the Lincoln Home NHS already manages and interprets the original Lincoln house and specifically tells the story of the additions to the property over time. Instead of helping interpret the original home, reconstruction of a conjectural earlier building located several blocks away could lead to visitor confusion and would violate agency policy. For this reason, the reconstructed building is an unneeded and inappropriate addition to the Lincoln Home NHS.

2. The proposed boundary expansion is not identified as a future need in the Lincoln Home NHS approved general management plan.

The boundary expansion proposed in S. 1812 was never contemplated or considered in the park’s 2010 draft general management plan5https://planning.nps.gov/document.cfm?parkID=147&projectID=13436&documentID=34332 (GMP); nor was it included or approved in the 2012 record of decision 6https://planning.nps.gov/document.cfm?parkID=147&projectID=13436&documentID=46149 (ROD) for the final GMP. As described in the ROD, “[t]he purpose of the GMP/EIS is to provide a comprehensive direction for resource preservation and visitor use, direction for management of the site, including its resources and visitors, and a basic foundation for decision making for the park for the next 15 to 20 years.” Because neither proposed donation was considered in the park GMP, it would be inappropriate for NPS to proceed without additional planning, such as a GMP amendment, which should include the opportunity for public comment.

3. The proposed legislation would impose an additional financial burden on the NPS.

The legislation (S. 1812) would require that the NPS accept, manage, and maintain the reconstructed Lincoln home and the Elijah Iles House. The Iles property has been moved several times, which is also problematic under the Secretary of Interior Standards. The building currently exhibits a collection of pre-civil war furniture and has only a tangential relationship to the Lincoln story. Again, the NPS would become responsible for ongoing management and maintenance of this property.

As a practical matter given the magnitude of the NPS deferred maintenance backlog, it would be imprudent for the NPS to assume responsibility for operation and maintenance of the proposed donated structures at Lincoln Home NHS. As reported by NPS7https://www.nps.gov/subjects/infrastructure/upload/NPS-Deferred-Maintenance-FY18-State_and_Park_2018.pdf Lincoln Home NHS had a deferred maintenance backlog of $6,394,871 at the end of FY 2018. This is more than twice the park’s FY 2021 ONPS budget justification of $2.767 million. See FY 2021 Greenbook8https://www.doi.gov/sites/doi.gov/files/uploads/fy2021-budget-justification-nps.pdf p. ONPS-96.

4. There are potentially more appropriate alternatives than expanding the boundaries of the Lincoln Home NHS.

The NPS, the people of Illinois, and their congressional delegation recognized the need to tell the full story of Abraham Lincoln’s formative years in the central part of Illinois. For this purpose, the Abraham Lincoln National Heritage Area9https://www.nps.gov/places/abraham-lincoln-national-heritage-area.htm was designated in 2008. The heritage area works in partnership with Lincoln Home National Historic Site to tell the story of Lincoln’s almost 30 years in the state in communities where Lincoln worked, traveled, and lived. The heritage area is managed by Looking for Lincoln10https://www.lookingforlincoln.org/, an organization that works with the communities and other partners to enhance Lincoln associated heritage sites within the region.

As described in the management plan11https://www.lookingforlincoln.org/ckfinder/connector?command=Proxy&lang=en&langCode=en&type=Files&currentFolder=%2F&hash=c245c263ce0eced480effe66bbede6b4d46c15ae&fileName=alnha-executive-summary.pdf for the Abraham Lincoln National Heritage Area, one of the area’s goals is “to assist initiatives for the preservation and stewardship of the region’s physical legacy of historic resources.” Thus, it seems that working within the framework of the national heritage area offers a compelling alternative to the proposed boundary expansion of the national historic site. Undertaken as a partnership project outside of the control of the NPS would allow for more flexible management; and would have less of a budgetary impact upon Lincoln Home NHS and its preservation of the original home. Another goal of the national heritage area is to ‘promote heritage, cultural, and recreational tourism and related heritage development that support increased economic activity and investment in heritage resources.” This function of the national heritage area appears to more closely align with the goals of the project proponents than that NPS’s management of Lincoln Home National Historic Site.

In conclusion, there are clear policy, management planning, and budgetary reasons why the Coalition does not support the proposed boundary expansion and donation of a reconstruction of the Lincoln Cottage and the Elijah Iles House as additions to Lincoln Home NHS. We urge the Illinois Congressional delegation to pursue other alternatives such as working with the Abraham Lincoln National Heritage Area. At a minimum, if such a boundary change is to be pursued, the National Park Service should go through a proper planning process, such as a formal resource study of the proposed additions and/or a general management plan amendment that allows for public involvement, before finalizing such a decision.

Thank you for your consideration.

Phil Francis Signature

 

 

 

Philip A. Francis, Jr., Chair
Coalition to Protect America’s National Parks

cc:
The Honorable Richard Durbin, U.S. Senator
The Honorable Tammy Duckworth, U.S. Senator
The Honorable Rodney Davis, U.S. Congressman, 13th District of Illinois
Shawn Benge, Acting Director, National Park Service
Joy Beasley, Associate Director, Cultural Resources, Partnerships, and Science, NPS
Bert Frost, Midwest Regional Director, National Park Service
Tim Good, Superintendent, Lincoln Home National Historic Site

 

 


CPANP Letterhead

 

 

August 19, 2021

The Honorable Raul Grijalva, Chairman
Committee on Natural Resources
U.S. House of Representatives
1324 Longworth House Office Building
Washington, DC 20515

The Honorable Bruce Westerman, Ranking Member
Committee on Natural Resources
U.S. House of Representatives
1324 Longworth House Office Building
Washington, DC 20515

Subject: Opposition to H.R. 3818– A bill to expand Lincoln Home National Historic Site

Dear Chairman Grijalva and Ranking Member Westerman:

I am writing on behalf of over 1,900 members of the Coalition to Protect America’s National Parks (Coalition), whose membership is comprised of retired, former, or current National Park Service (NPS) employees. As a group we collectively represent over 40,000 years of experience managing and protecting America’s most precious and important natural and cultural resources. Among our members are former NPS directors, regional directors, superintendents, resource specialists, rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.

The Coalition is very concerned about the Lincoln Home National Historic Site Boundary Modification Act (H.R. 3818). The legislation proposes to expand the boundary of the Lincoln Home National Historic Site (Lincoln Home or NHS) in Springfield, Illinois, to incorporate a donated reconstruction of “Lincoln’s Springfield cottage”, as well as the historic Elijah Iles House.

As background,”[ t]he Lincoln Home was the first and only home Abraham Lincoln owned and still stands today, with much of the original structure, walls, and foundations remaining… It’s growth and expansion mirrors the growth of the Lincoln family from a young couple with a baby, to a presidential family bound for the White House, as well as Lincoln’s growth from a young lawyer of humble origin to the highest position in the United States.”12https://www.nps.gov/liho/learn/historyculture/the-lincoln-home.htm

As proposed, the Abraham Lincoln Association, a friends group incorporated to provide financial support to Lincoln sites and research, would acquire a vacant lot near Lincoln Home NHS, then construct and donate a replica of the “cottage” as it may have appeared before it was expanded by the Lincolns multiple times. Please understand that while the Lincolns lived in the home from 1844-1861, the original “cottage” only accounted for two years of that occupancy. It had been constructed in 1839 for the Reverend Charles Dresser; then purchased and moved into by the Lincoln family in 1844. The Lincolns subsequently made multiple additions and changes to the structure in 1846, 1849-1850, 1853, 1855, 1856, and then again in1859.13https://www.nps.gov/liho/learn/historyculture/homechronology.htm  After the Lincolns moved to the White House, the home remained in the Lincoln family; however, it was occupied by a series of tenants from 1861 until the home was donated to the State of Illinois in 1887.

Given that historical context, the primary effect of the legislation would be to expand the boundary of Lincoln Home National Historic Site to incorporate a replica structure of a cottage that the Lincolns lived in for only two years; and that replica would be located at a site that is not associated with the original Lincoln home. The legislation would also incorporate a nearby historic structure, the Elijah Iles House, into the NHS that is otherwise unaffiliated with the Lincolns.

As a result, the legislation raises serious concerns about the NPS accepting properties into the National Park System under conditions that do not conform to the agency’s cultural resource regulations and policies; and that do not meet the goals of the national historic site’s general management plan (GMP).

While the proposal may be well-intended, we believe these properties would not be appropriate additions to Lincoln Home NHS for the following reasons:

1. The proposed boundary expansion and the plan to reconstruct a Lincoln Home from an earlier period do not conform to the Secretary of the Interior’s Standards for the Treatment of Historic Properties and NPS Management Policies.14https://www.nps.gov/tps/standards.htm

The Lincoln Home National Historic Site in Springfield IL was established in 1971 for the purpose as stated in its enabling legislation “to preserve and interpret for the benefit of present and future generations the home of Abraham Lincoln in Springfield, Illinois.” Pub. L. 92–127, Aug. 18, 1971, 85 Stat. 347. It also interprets a four-block area with the original Lincoln Home as the centerpiece of the site. Today, the Lincoln Home is fully interpreted to the period of 1844 -1861, including changes made by the Lincoln family to the property.

The National Historic Preservation Act (1966) authorized the promulgation of regulations on the treatment of historic resources. The Secretary of the Interior’s Standards for the Treatment of Historic Properties were developed by the National Park Service in 1978 and were later codified in the Federal Register (36 CFR 68.3) in 1995. At the same time, guidelines were also published to assist in their implementation of the standards. These guidelines were updated in 2017. These standards and guidelines are a critical part of the framework of the national preservation program and are widely used at the federal, state, and local levels across the nation.

The standards specifically speak to the issue of “reconstruction”. It is defined as “the act or process of depicting, by means of new construction, the form, features, and detailing of a non-surviving site, landscape, building, structure, or object for the purpose of replicating its appearance at a specific period of time and in its historic location.” The standards do not encourage this practice and state that reconstruction should be undertaken only if it can be done with a minimum of conjecture and, most relevant to this matter at hand, if the reconstruction “…is essential to the public’s understanding of the property.” 36 CFR 68.3 (d) (1).

More specifically, NPS Management Policies 2006 15https://www.nps.gov/policy/mp/policies.html limits “reconstruction of missing historic structures” in Section 5.3.5.4.4, which states: “No matter how well conceived or executed, reconstructions are contemporary interpretations of the past rather than authentic survivals from it. The National Park Service will not reconstruct a missing structure unless (emphasis added):

there is no alternative that would accomplish the park’s interpretive mission;
• sufficient data exist to enable its accurate reconstruction based on the duplication of historic features substantiated by documentary or physical evidence rather than on conjectural designs or features from other structures;
reconstruction will occur in the original location;
• the disturbance or loss of significant archeological resources is minimized and mitigated by data recovery; and
reconstruction is approved by the Director.

It behooves the NPS, as the nation’s leading historic preservation agency, to adhere to its own best management practices. In this case, the Lincoln Home NHS already manages and interprets the original Lincoln house and specifically tells the story of the additions to the property over time. Instead of helping interpret the original home, reconstruction of a conjectural earlier building located several blocks away could lead to visitor confusion and would violate agency policy. For this reason, the reconstructed building is an unneeded and inappropriate addition to the Lincoln Home NHS.

2. The proposed boundary expansion is not identified as a future need in the Lincoln Home NHS approved general management plan.

The boundary expansion proposed in H.R. 3818 was never contemplated or considered in the park’s 2010 draft general management plan16https://planning.nps.gov/document.cfm?parkID=147&projectID=13436&documentID=34332 (GMP); nor was it included or approved in the 2012 record of decision17https://planning.nps.gov/document.cfm?parkID=147&projectID=13436&documentID=46149 (ROD) for the final GMP. As described in the ROD, “[t]he purpose of the GMP/EIS is to provide a comprehensive direction for resource preservation and visitor use, direction for management of the site, including its resources and visitors, and a basic foundation for decision making for the park for the next 15 to 20 years.” Because neither proposed donation was considered in the park GMP, it would be inappropriate for NPS to proceed without additional planning, such as a GMP amendment, which should include the opportunity for public comment.

3. The proposed legislation would impose an additional financial burden on the NPS.

The legislation (H.R. 3818) would require that the NPS accept, manage, and maintain the reconstructed Lincoln home and the Elijah Iles House. The Iles property has been moved several times, which is also problematic under the Secretary of Interior Standards. The building currently exhibits a collection of pre-civil war furniture and has only a tangential relationship to the Lincoln story. Again, the NPS would become responsible for ongoing management and maintenance of this property.

As a practical matter given the magnitude of the NPS deferred maintenance backlog, it would be imprudent for the NPS to assume responsibility for operation and maintenance of the proposed donated structures at Lincoln Home NHS. As reported by NPS18https://www.nps.gov/subjects/infrastructure/upload/NPS-Deferred-Maintenance-FY18-State_and_Park_2018.pdf, Lincoln Home NHS had a deferred maintenance backlog of $6,394,871 at the end of FY 2018. This is more than twice the park’s FY 2021 ONPS budget justification of $2.767 million. See FY 2021 Greenbook19https://www.doi.gov/sites/doi.gov/files/uploads/fy2021-budget-justification-nps.pdf , p. ONPS-96.

4. There are potentially more appropriate alternatives than expanding the boundaries of the Lincoln Home NHS.

The NPS, the people of Illinois, and their congressional delegation recognized the need to tell the full story of Abraham Lincoln’s formative years in the central part of Illinois. For this purpose, the Abraham Lincoln National Heritage Area20https://www.nps.gov/places/abraham-lincoln-national-heritage-area.htm was designated in 2008. The heritage area works in partnership with Lincoln Home National Historic Site to tell the story of Lincoln’s almost 30 years in the state in communities where Lincoln worked, traveled, and lived. The heritage area is managed by Looking for Lincoln21https://www.lookingforlincoln.org/ , an organization that works with the communities and other partners to enhance Lincoln associated heritage sites within the region.

As described in the management plan22https://www.lookingforlincoln.org/ckfinder/connector?command=Proxy&lang=en&langCode=en&type=Files&cur rentFolder=%2F&hash=c245c263ce0eced480effe66bbede6b4d46c15ae&fileName=alnha-executive-summary.pdf for the Abraham Lincoln National Heritage Area, one of the area’s goals is “to assist initiatives for the preservation and stewardship of the region’s physical legacy of historic resources.” Thus, it seems that working within the framework of the national heritage area offers a compelling alternative to the proposed boundary expansion of the national historic site.
Undertaken as a partnership project outside of the control of the NPS would allow for more flexible management; and would have less of a budgetary impact upon Lincoln Home NHS and its preservation of the original home. Another goal of the national heritage area is to ‘promote heritage, cultural, and recreational tourism and related heritage development that support increased economic activity and investment in heritage resources.” This function of the national heritage area appears to more closely align with the goals of the project proponents than that NPS’s management of Lincoln Home National Historic Site.

In conclusion, there are clear policy, management planning, and budgetary reasons why the Coalition does not support the proposed boundary expansion and donation of a reconstruction of the Lincoln Cottage and the Elijah Iles House as additions to Lincoln Home NHS. We urge the Illinois Congressional delegation to pursue other alternatives such as working with the Abraham Lincoln National Heritage Area. At a minimum, if such a boundary change is to be pursued, the National Park Service should go through a proper planning process, such as a formal resource study of the proposed additions and/or a general management plan amendment that allows for public involvement, before finalizing such a decision.

Thank you for your consideration.

Sincerely,

Phil Francis Signature

 

 

 

Philip A. Francis, Jr., Chair
Coalition to Protect America’s National Parks

cc:
The Honorable Rodney Davis, U.S. Representative, 13th District of Illinois
The Honorable Chuy Garcia, U.S. Representative, 4th District of Illinois
The Honorable Darin LaHood, U.S. Representative, 18th District of Illinois
Shawn Benge, Acting Director, National Park Service
Joy Beasley, Associate Director, Cultural Resources, Partnerships, and Science, NPS
Bert Frost, Midwest Regional Director, National Park Service
Tim Good, Superintendent, Lincoln Home National Historic Site