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HomeMy WebLinkAboutPlum Island Lighthouse • o�gUEf��oo James Garretson,Chairperson �� Town Hall Annex Anne Surchin,-Vice Chair 54375 Route 25 Donald Feiler P6 Box 1179 James Grathwohl d,j, �► !� Southold,NY 11971 Robert Harper '�(�! �.�® Fax(631)765-9502 Gary Parker Telephone: (631)765-1802 Edward Webb www.southoldtownny.gov Damon Rallis,,Administrative Assistant Town of Southold Historic Preservation Commission June 19, 2018 RESOLUTION #6.19.1 Direct the Chairman to Request a Meeting with the Supervisor and Town Board RE: Plum island Lighthouse RESOLUTION: WHEREAS, Plum Island Lighthouse is listed on the State and National Registers of Historic Places, and Town of Southold Registry of Historic Landmarks, and WHEREAS, the structure is at risk due to lack of maintenance and neglect, and WHEREAS, members of the Southold Town Historic Preservation Commission met with'the Southold Town Board on October 10, 2017 to discuss the issue, and WHEREAS, there has been no action on the part of the Federal government to remedy the situation, NOW THEREFORE BE IT RESOLVED,that the Southold Town Historic Preservation Commission authorizes and directs Chairman James Garretson to schedule a meeting with Southold Town Supervisor Scott Russell and the Southold Town Board to urge them to join in calling upon our elected congressional representatives to take immediate action to urge the Department of Homeland Security to fulfill its mandated historic preservation responsibilities relating to the Plum Island Lighthouse. MOVER: SECONDER: AYES: RESULT: Signed: Damon Peter Rallis,Application Coordinator for the Historic Preservation Commission Date: ��pf 80UTy0 James Garretson,Chairperson Town Hall Annex Anne Surchin,Vice Chair 54375 Route 25 Donald Feiler a PO Box 1179 James Grathwohl o Southold,NY 11971 Robert Harper �� a Fax(631)765-9502 Gary Parker Telephone: (631)765-1802 Edward Webb www.southoldtownny.gov Damon Rallis,Administrative Assistant Town of Southold - historic Preservation Commission June 19, 2018 Re: The Plum Island Lighthouse Dear Scott, You may recall that commissioners met with you and the Southold Town Board in October of last year to discuss a dire situation at the Plum Island Lighthouse, which is at risk due to neglect and a lack of maintenance. I am contacting you today to request a follow-up meeting with you and the town board and to, once again, strongly recommend that Southold Town call upon our local Congressional representatives to assure the federal government takes steps necessary to preserve this historic town landmark before it is too late. As you know, the mission of the Historic Preservation Commission is to identify and protect structures like these from incompatible alterations or demolition. This ensures that alterations to a building's exterior retain its architectural integrity. Attached, please find a summary of our findings. We respectfully request that you share this information with the rest of the Southold Town Board. Thank you for your prompt consideration on this critical matter. Sincerely, James Garretson, Chair Southold Town Historic Preservation The Plum Island Lighthouse was listed on the New York State Register of Historic Places on 11 May 2003. On 16 November 2004 it became a Town of Southold Designated Landmark(by virtue of its listing on the State Register prior to the enactment of Chapter 170 of the Town Code). On 11 February 2011 the Plum Island Lighthouse was listed on the National Register of Historic Places. The lighthouse remains a significant visual feature of the Town of Southold and plays an important role in local heritage tourism activities. The US Coast Guard owned and operated the Lighthouse until 1978 when it was deactivated. At that time ownership was transferred to the US Department of Agriculture (USDA) which operated the Plum Island Animal Disease Center(PIADC). USDA and PIADC became responsible for the lighthouse at that time. USDA continued to own and maintain the lighthouse until 2003 when Plum Island and the Lighthouse were transferred to the Department of Homeland Security(DHS). Just prior to its transfer to DHS, the USDA commissioned a historic preservation plan for,all of Plum Island, including the Lighthouse. The plan noted that the No Action option would constitute an adverse effect under the National Historic Preservation Act. The plan concluded that the integrity of the lighthouse and its character-defining features would be threatened by continued neglect and exposure to the weather. The historic preservation plan estimated that continued maintenance of the lighthouse was expected to cost approximately $0-$15,000 annually. It noted that for "many years, the PIADC [while under the control of USDA] has pursued the maintenance option to prevent further deterioration. The Plum Island Lighthouse roof periodically has been repaired and new sash installed in several places" (p.6-2). The plan recommended that "PIADC continue the Maintenance option for the Plum Island Lighthouse and ancillary buildings. Regular painting, reroofing, and maintenance of the window sash and doors should be carried out as needed and with appropriate materials. Because the interior has been drastically altered, no additional interior repairs are recommended, although roof leaks should be monitored to prevent further damage to the interior's few original wood features" (p.6-3). In 2008 in a mandated report to the Advisory Council on Historic Preservation and the Secretary of the Interior, DHS stated that future management of the lighthouse would be guided by the preservation plan. In 2008 DHS also commissioned a lead paint and asbestos abatement survey of the Lighthouse, but did not implement actual abatement measures, presumably because of the estimated associated costs. Based on observations of the current exterior condition of the Lighthouse, it appears that DHS is permitting significant deterioration of at least the lighthouse components exposed to the weather to occur. This deterioration is readily apparent in comparisons of photographs taken in 2008 and 2018 (attached). How the failure to maintain the exterior may have affected the interior structure is unknown. DHS is seemingly failing to comply with its historic preservation responsibilities in regard to the Lighthouse as specified in law, regulation, and its own department procedures, policies, and guidance (see attached analysis). X i 1 Amps,f� r 1 ^ r ` � 3'�r' '� � } ` 1 fixes�•I�x r v A a Z� T J •+` d ^ � � � �� L 1 I4 �� � �s BEY S +y now 4y b� rA t 11 '! Fix' r e ¢� r AM- so AlT I � }�C`����1>�k ,�1 ,riv:���!I `�.. ••�: r t:.� 5 r f'�,1 n ,'J s s NOV q9 ���^ �3� r art :% i 1 ,t •, �I iifif�#j` �iy t7 Yx� I{•�_' �r�iyy�� t } WIN j .min oil 1 s r � a Vt. A 41 r 3„ *h • vY h 3 ll # — x t ' s 77 V ? _ r✓t r n a ,s�' � ,,, �?�; ,�k �� # ��� r�r..`s'r,�,*�,�,.;' .x.•��r;ww _ i y �.r•�.3;gc — •s A ttppyy � ,: .f ✓ a -• � � r fir±— � r .� � }��. XC .s A Review of the Department Of Homeland Security's Compliance with Its Obligations, Responsibilities and Commitments Regarding the Preservation and Maintenance of the Plum Island Lighthouse—A Property Listed on the National Register of Historic Places The Department of Homeland Security and the Plum Island Animal Disease Center are not complying with their historic preservation responsibilities and commitments as they relate to the Plum Island Lighthouse as specified in the following statutes, regulations, guidance, and department policies: • Section 110 of the National Historic Preservation Act of 1966, as amended • Executive Order 13287 of March 3, 2003 (Preserve America) • DHS Directives System Directive Number: 017-01, Historic Preservation in Asset Management and Operations (March 10, 2008) • Record Of Decision, Public Sale Of Plum Island, New York (August 29, 2013) • The 2003 Plum Island Historic Preservation Plan Section 110 of the National Historic Preservation Act(PL 89-665;54 U.S.C.300101 et seq.) Section 110 of the National Historic Preservation Act sets forth the responsibilities of Federal agencies, including DHS, regarding the management of properties like the Plum Island Lighthouse that are listed on the National Register of Historic Places (NRNP). It also specifically authorizes the use of agency funds to carry out Section 110 responsibilities. The relevant portions of Section 110 are as follows: (a) (1) The heads of all Federal agencies shall assume responsibility for the preservation of historic properties which are owned or controlled by such agency. Each agency shall undertake, consistent with the preservation of such properties and the mission of the agency and the professional standards established pursuant to section 101(8) of this Act, any preservation, as may be necessary to carry out this section. (b) that such properties under the jurisdiction or control of the agency as are listed in or may be eligible for the National Register are managed and maintained in a way that considers the preservation of their historic, archaeological, architectural, and cultural values in compliance with section 106 of this Act. . . (g) Each Federal agency may include the costs of preservation activities of such agency under this Act as eligible project costs in all undertakings of such agency or assisted by such agency. Executive Order 13287 of March 3,2003 (Preserve America)(FR 68:10635-10638) Section 1 of EO 13287 states that it "is the policy of the Federal Government to provide leadership in preserving America's heritage by actively advancing the protection, enhancement, and contemporary use of the historic properties owned by the Federal Government. . . [and] Where consistent with executive branch department and agency missions, governing law, applicable preservation standards, and where appropriate, executive branch departments and agencies ("agency" or "agencies") shall advance this policy through the protection and continued use of the historic properties owned by the Federal Government." Section 3(a) of EO 13287 states in part: "Accurate information on the state of Federally owned historic properties is essential to achieving the goals of this order and to promoting community economic development through local partnerships. Each agency with real property management responsibilities shall prepare an assessment of the current status of its inventory of historic properties required by section 110(a)(2) of the NHPA (16 U.S.C. 470h-2(a)(2)), the general condition and management needs of such properties, and the steps underway or planned to meet those management needs. The assessment shall also include an evaluation of the suitability of the agency's types of historic properties to contribute to community economic development initiatives, including heritage tourism, taking into account agency mission needs, public access considerations, and the long term preservation of the historic properties." Section 3(b) of EO 13287 states in part: "Each agency with real property management responsibilities shall, by September 30, 2005, and every third year thereafter, prepare a report on its progress in identifying, protecting, and using historic properties in its ownership and make the report available to the [Advisory Council on Historic Preservation]and the Secretary." DHS prepared and submitted the requisite reports in 2008, 2011, 2014, and 2017. All of these reports make specific mention of Plum Island. The 2008 report states that "the future management of . . . the Plum Island Light Station, will be guided by the [2003] Historic Preservation Plan prepared by PIADC in consultation with the New York SHPO" (p.5). All of the subsequent reports drop the reference to the historic preservation plan and state only that the DHS Science & Technology Directorate "partners with lighthouse enthusiasts to allow access to the Plum Island Lighthouse for exterior tours; the interior of the lighthouse is off limits to the public because of environmental hazards" (2011:6). Section 4 of EO 13287 specifically addresses Federal stewardship of historic properties: (a) Each agency shall ensure that the management of historic properties in its ownership is conducted in a manner that promotes the long-term preservation and use of those properties as Federal assets and, where consistent with agency missions, governing law, and the nature of the properties, contributes to the local community and its economy. DHS Directive Number: 017-01, Historic Preservation in Asset Management and Operations (March 10, 2008) Section I of Directive 017-0: "establishes policy and procedures for appropriate consideration of historic properties and sacred sites in the management and operation of the full range of the Department of Homeland Security(DHS)assets." Section V.A states that: "DHS will integrate appropriate preservation of the historic and cultural aspects of the nation's heritage into performing the homeland security mission. Consistent with its mission requirements and other mandates of public policy, DHS will identify and protect the significant material remains of the Nation's historical and cultural foundations as a living part of its community life and development in order to give a sense of orientation to the American people. Section V.D.4 states that DHS will: "Budget for sufficient resources, in project planning and execution processes to allow for appropriate identification, evaluation, and treatment of impacts to historic properties. . ." Record of Decision, Public Sale of Plum Island, New York(August 29,2013) In September 2008 Congress passed the Consolidated Security, Disaster Assistance and Continuing Appropriations Act of 2009 (Public Law 110-329) authorized the transfer of Plum Island out of Federal (DHS) ownership by way of public sale. Pursuant to requirements of the National Environmental Policy Act (NEPA) DHS and the General Services Administration (GSA), acting as Joint Lead Agencies, prepared Draft and Final Environmental Impact Statements (DEIS and FEIS))for the sale of Plum Island.The EIS process culminated in the preparation in 2013 of a Record of Decision (ROD) which documented the decision to proceed with the sale of Plum Island, including the Plum Island Lighthouse. The ROD states: "In accordance with Section 110 of NHPA, DHS will identify, nominate to the NR, and protect historic properties under its ownership. Pursuant to these requirements, the Plum Island Light House was nominated and listed on the NR in 2011. In addition, the Joint Lead Agencies are currently developing NR nominations for additional eligible historic properties located on Plum Island, such as those associated with a former military fortification known as Fort Terry. While Plum Island remains in federal ownership, DHS will continue to comply with its Section 110 responsibilities"(2013 ROD, p.4)(emphasis added). Signatories to the ROD are: Dr. Teresa R. Pohlman, Director, Sustainability & Environmental Programs Office of the Chief Readiness Support Officer, Department of Home land Security; Robert Zarnetske, Regional Administrator, New England Region, General Services Administration; and Glenn C. Rotondo, Regional Commissioner, New England Region, Public Buildings Service, General Services Administration. Historic Preservation Plan for Plum Island(May 2003) In 2003 the USDA commissioned a historic preservation plan for Plum Island. Section 6 of that plan discussed treatment plans for the Plum Island Lighthouse. Six proposed treatment options for the historic properties-no action, maintenance, demolition, preservation (mothballing), rehabilitation, and relocation--were analyzed and evaluated. The Historic Preservation Plan states: "Because further deterioration of the NRHP-listed[Plum Island Lighthouse is]expected to continue under this option, the No Action option constitutes an adverse effect on the buildings as defined in Section 110 of the National Historic Preservation Act]. The integrity of the [lighthouse and its]character-defining features, and[its]setting will be threatened by continued neglect and exposure to the weather. . . The No Action option is not recommended"(p.6-1);and "The Maintenance option involves continued monitoring of the buildings'conditions. The buildings/structures are periodically checked for deterioration and for erosion of the surrounding setting. Essential features of the buildings, such as roofs, windows, and doors are repaired and replaced as needed in a timely manner using appropriate materials. The buildings are secured against unauthorized entry and are, treated for rodent and pest infestation as needed. . . Costs involved with maintaining a structure are less than the other active alternatives. (F)or cost comparison purposes, continued maintenance of the Lighthouse is expected to cost approximately$0-$15,000 annually. . . For many years, the PIADC has pursued the maintenance option to prevent further deterioration. The Plum island Lighthouse roof periodically has been repaired and new sash installed in several places"(p.6-2); and "It is recommended that the PIADC continue the Maintenance option for the Plum island Lighthouse and ancillary buildings. Regular painting, reroofing, and maintenance of the window sash and doors should be carried out as needed and with appropriate materials. Because the interior has been drastically altered, no additional interior repairs are recommended, although roof leaks should be monitored to prevent further damage to the interior's few original wood features"(p.6-3); and "relocation and reconstruction of the Lighthouse off Plum Island with abatement is expected to be approximately$1,500,000"(p.6-11); and "Relocation is not recommended for the Plum Island Lighthouse. Relocation would have an adverse impact as defined by Section 110 and would necessitate dismantling the lighthouse. Relocation to another location on Plum Island would be pointless and relocation to the mainland would destroy its historical association with Plum Island and maritime navigation"(p.6-13); and "It is recommended that the Lighthouse complex . . . continue to be maintained by PIADC, in accordance with their current operating practices, to prevent further deterioration. This has included periodic repairs of the exterior of the Lighthouse and ancillary buildings including regular painting, re-roofing, and maintenance of the windows and doors"(p.9-2).