NATIONAL PARK SERVICE

RECORD OF DECISION

The Department of the Interior, National Park Service (NPS) has prepared this Record of Decision on the Final General Management Plan and Environmental Impact Statement for Gettysburg National Military Park (NMP), Pennsylvania. This Record of Decision is a statement of the background of the project, the decision made, the basis for the decision, other alternatives considered, the environmentally preferable alternative, measures to minimize environmental harm, and the public involvement in the decision making process.

Gettysburg NMP, located in Adams County, Pennsylvania, was established to preserve the nationally significant resources of the Battle of Gettysburg, the Soldiers' National Cemetery and the commemoration and preservation of the battlefield. The battle was the largest and most costly in human terms to occur on the North American continent. It lessened the Confederacy’s ability to successfully wage war and contributed to the ultimate preservation of the United States. The creation of the Soldiers' National Cemetery, and Abraham Lincoln’s Gettysburg Address, heightened Americans’ sense of the meaning and importance of the war. The national park inspired by those who experienced the Civil War preserved major features of the 1863 battlefield and commemorated the valor and sacrifice of the participants. These elements make Gettysburg a place where Americans continue to remember and honor those whose struggle led to a united nation.

As part of its compliance with the Government Performance and Results Act of 1993, NPS developed for each unit of the national park system a legislative purpose statement, a mission statement and mission goals. NPS developed these elements in consultation with the Pennsylvania State Historic Preservation Officer, the Gettysburg National Military Park Advisory Commission, other interested agencies and organizations, and the public.

The legislated purposes of Gettysburg NMP are:

• To preserve the topographical, natural and cultural features that were significant to the outcome of the Battle of Gettysburg.
• To mark the lines of battle, and to preserve the monuments and markers that commemorate the struggle.
• To provide opportunities for people to learn about the Battle of Gettysburg in the full social, political and cultural context of the Civil War and American History.
• To preserve the objects, artifacts and archives that document the battle, its aftermath and commemoration.

The mission that NPS has established for Gettysburg NMP is:

The four mission goals that NPS established for Gettysburg NMP are:

• The landscapes, buildings, monuments, structures, archeological sites, artifacts and archives that are significant to the outcome and commemoration of the Battle of Gettysburg are protected, rehabilitated and maintained in good condition.
• The public understands and appreciates the significant events associated with the Gettysburg Campaign and its impact upon the development of the nation.
• Visitors safely enjoy high quality educational experiences accessible to all segments of the population.
• Public and private entities understand the park’s mission and act cooperatively to protect and interpret resources related to the Gettysburg Campaign and its commemoration.

The purpose of a General Management Plan/Environmental Impact Statement (GMP/EIS) is to set forth a basic management philosophy for a park and to provide a framework for future decision making. NPS’ Management Policies require that a park’s GMP be reviewed periodically and revised or amended as necessary to reflect new issues or management objectives, or when it has exceeded the period for which it was developed, which is usually 15 years. (NPS Management Policies, Chapter 2:6) The park’s last GMP was completed more than 17 years ago, in 1982; although the plan continues to be used as a general guide for operations, it is no longer adequate to address the policy and operational issues now facing the park’s managers.

Since the completion of the 1982 plan, the boundaries of the park have changed, adding more than 1/3^rd to its total acreage. NPS has determined that the park contains three nationally significant landscapes, only one of which NPS considered fully in the 1982 GMP. Some of the most important resources of the park are sustaining damage from visitors. In other cases, such as at Ziegler’s Grove, Culp’s Hill, and the second day’s battlefield, changes to the natural and built environment have obscured the underlying historic landscape of the battle. NPS surveys of its collections and archives revealed that lack of adequate, environmentally controlled storage space was causing these resources to deteriorate. The lack of an appropriately sized and environmentally controlled gallery for the cyclorama painting, "Battle of Gettysburg," meant that it, too, was sustaining damage. The park’s increasing visitation, the changing educational needs of its visitors, and the demands placed on its visitor infrastructure, exceed NPS’ ability to provide necessary services. Therefore, at Gettysburg NMP, a new GMP/EIS was needed to provide guidance for stewardship and interpretation of the park’s three nationally significant landscapes—the site of the Battle of Gettysburg, the Soldiers’ National Cemetery, and the commemorative landscape of avenues and monument—as well as its collections and archives. Consequently, the decision was made to begin a general management plan with an environmental impact statement in order to reach a decision regarding the specific resource conditions and visitor experiences that NPS should achieve and maintain at Gettysburg NMP.

NPS began the EIS process on May 5, 1997 with the publication in the Federal Register of a Notice of Intent to prepare a draft EIS. Scoping meeting were held to identify issues and concerns relating to the proposed general management plan. NPS published the Notice of Availability of the draft EIS in the Federal Register on August 18, 1998. The comment period on the draft ended October 17, 1998. NPS responded to substantive comments in the Final GMP/EIS, which was released on June 18, 1999. The Notice of Availability of the Final GMP/EIS appeared in the Federal Register on June 25, 1999.

The Final General Management Plan / Environmental Impact Statement has been prepared to satisfy the requirements of the National Environmental Policy Act (NEPA) of 1969, as amended, which requires the evaluation of potential impacts resulting from federal actions. It includes a description of the environment affected by the proposed activities and the environmental consequences of implementing any of the alternatives.

The Final General Management Plan / Environmental Impact Statement is a programmatic statement. The proposed action and alternatives consist of a basic management framework for future decision making; therefore, site-specific details and recommendations are not always included. Consequently, the statement presents an overview of potential impacts relating to the proposed program for each alternative. In the future, if NPS determines that specific actions called for by the approved plan require additional analysis of impacts, more detailed assessments of impacts may be prepared as part of necessary implementation planning. These documents will be tiered from this environmental impact statement.

In the process of preparing this GMP/EIS, NPS conducted new research and analysis on the battle and its relationship to the contested terrain. Based on careful study of period documents, NPS delineated those battlefield landscape features that were significant to the outcome of the battle, as well as the locations of combat. NPS also studied the features that characterize the Soldiers’ National Cemetery and the battle’s commemoration. In addition, NPS conducted an extensive assessment to compare present day landscape features to those that existed at the time of the battle. Through this work, NPS divided the resources of Gettysburg NMP into five priority and two other categories. Resources in Priority categories 1, 2, and 3 are essential to the reasons for which Gettysburg NMP was designated by Congress, and their preservation and rehabilitation is mandatory if NPS is to meet its legislative purposes at this park. Resources in Priority categories 4 and 5 include other types of resources, such as non-battle related wetlands, that NPS must consider according to law or NPS policies. Other categories included tools, such as visitor centers, and non-contributing features.

This information was used to delineate resource areas: the Major Battle Action Area, the Soldiers’ National Cemetery and the Battlefield Commemorative Area. Each of these resource areas contains a concentration of essential park resources. NPS must protect these resources in order to maintain unimpaired the values for which Congress designated the park. NPS used these resource areas to differentiate actions for the GMP alternatives.

In 1994, several years before the initiation by NPS of a new GMP for Gettysburg NMP, NPS had begun a process to consider changes to its visitor center and museum facilities. The current visitor center and museum facilities at Gettysburg NMP are located on land that was central to the Battle of Gettysburg and they are visible from large portions of the battlefield as contemporary intrusions on the battlefield’s

historic setting. In addition, the facilities are greatly inadequate to meet visitor and curatorial needs. For these reasons, construction of new museum and visitor center facilities in a more suitable location has long been an objective of the park. However, Federal funding limitations have effectively precluded the possibility of constructing replacement facilities with government funds.

The concept of a public/private cooperative effort to solve some of the visitor center and curatorial needs was first considered by NPS when a local developer proposed a new Cyclorama Building paired with a private IMAX theater on a piece of park-owned land. In order to respond to the unsolicited offer, NPS held three public workshops and in March 1995 developed a draft plan/environmental assessment to evaluate the proposal. After a total of 65 days of public and agency review, NPS decided to look at additional options for the building’s configuration and initiate a nationwide call for cooperators.

Between August 1995 and April 1996, NPS prepared a Draft Development Concept Plan / Environmental Assessment (DCP) to explore alternatives for the center. The DCP included four alternative concepts for the new facilities: a no action alternative; building a collections and archival storage facility and leaving the Cyclorama and Visitor Center as they are now; renovating the existing Visitor Center in place and building a new Cyclorama Building with collections storage; and building a new combined facility incorporating all these uses on a site removed from significant battle action (the preferred option indicated in the Draft DCP/EA). As a part of the development of this plan, NPS held a series of workshops, focus group meetings, and community presentations for the purpose of understanding public concerns, writing goals for the facility, and developing criteria for judging proposals and sites.

After considering public comments on this concept plan, in 1996 NPS issued a Request for Proposals, Visitor Center and Museum Facilities, Gettysburg National Military Park (RFP). The RFP solicited specific proposals from non-Federal sources to enter into a cooperative agreement with NPS to provide new visitor center and museum facilities either on park land or on non-park land in the vicinity of the park. The terms of the RFP invited creative proposals from all possible sources with few limitations so long as they furthered the NPS goals for the new facilities. The RFP required that proposals suggest a site for the facilities within a specific area of consideration (extending beyond the boundaries of the park). Among other matters, the RFP noted that a reevaluation of environmental issues would be a part of the process for entering any agreement, and that depending on the proposal an amendment to the current General Management Plan might be required.

NPS, as of the RFP closing date of May 16, 1997, received six proposals. On November 8, 1997, the Director of the National Park Service announced that it had selected a proposal for negotiation. NPS selected the proposal because it offered to have a non-profit corporation provide the facilities sought by NPS on an excellent site and ultimately would result in the donation of the facilities to Gettysburg NMP.

Although the proposal was judged as the best overall proposal received in response to the RFP, NPS pointed out that there were aspects of the proposal that needed to be negotiated in order to achieve an acceptable cooperative agreement. As part of this process, NPS sought public comment on the proposal through environmental and other public review processes between November 1997 and spring 1998.

Scoping for the park’s new General Management Plan and Environmental Impact Statement had been initiated in April 1997. Based on public input received from the DCP, the GMP/EIS and other public comment, NPS determined that it was desirable to incorporate the issues of visitor use and interpretation at the visitor center and museum facilities as an element of its forthcoming draft GMP/EIS.

Relationship of the General Management Plan to Other Plans and Processes

1990 Boundary Legislation/1993 Land Protection Plan: The GMP/EIS is based upon the park boundaries defined by Public Law 101-377, An Act to Revise the Boundary of Gettysburg National Military Park. The priorities and planned actions for protecting lands within the 1990 boundary are detailed in the park’s 1993 Land Protection Plan. The action alternatives in the GMP/EIS describe several minor boundary adjustments and other actions needed to address deficiencies in the 1990 legislation and the 1993 Land Protection Plan.

1995 White-tailed Deer Management Plan /Environmental Impact Statement: In 1994, NPS released a draft white-tailed deer management plan and environmental impact statement (white-tailed deer management plan). This white-tailed deer management plan reviewed alternatives for managing the population of white-tailed deer at Gettysburg NMP and Eisenhower NHS. In June 1995, NPS approved the white-tailed deer management plan and a record of decision was signed. NPS determined in the white-tailed deer management plan that a deer density of 25 deer per forested square mile must be maintained at Gettysburg NMP and Eisenhower National Historic Site. There is nothing in the GMP/EIS for Gettysburg NMP that will affect this desired deer density, hence the white-tailed deer management plan is not affected by the GMP/EIS.

Government Performance and Results Act Strategic Park Management Plan: In 1997, NPS developed a systemwide plan to meet the requirements of the Government Performance and Results Act of 1993. As previously noted, as a part of its compliance with this act, NPS develops for each unit of the national park system a new significance statement, legislative purpose statements, mission statement, mission goals and long term goals to guide management of the park (the Strategic Park Management Plan). At Gettysburg National Military Park, this plan was developed in consultation with the State Historic Preservation Officer, the Gettysburg National Military Park Advisory Commission, other interested agencies and organizations, and the general public. The action alternatives developed in the GMP/EIS are based upon the significance, purpose, mission and mission goals outlined in the park’s Strategic Park Management Plan.

The National Park Service will implement Alternative C, the proposed plan, (the selected action), as described in the Final General Management Plan and Environmental Impact Statement issued in June 1999.

The intent of the selected action is to rehabilitate the Gettysburg battlefield so that the features that were significant to the outcome of the battle and its commemoration more nearly reflect their historic conditions. The selected action will identify and protect the resources that contribute to the park’s national significance, including its three nationally significant landscapes: the site of the Battle of Gettysburg, the Soldiers’ National Cemetery, and the commemorative landscape of avenues and monuments built by the battle’s veterans. Through the construction of new museum and collections storage facilities, the selected action will also provide improved protection for the cyclorama painting, a National Historic Object, and for the park’s extensive collections and archives. The combination of rehabilitated historic landscapes and improved museum interpretation in the new facility will allow visitors to understand the Battle of Gettysburg, its aftermath and commemoration within the full context of American history. Because the present Visitor Center and Cyclorama Building are located virtually on Ziegler’s Grove, one of the most historically significant areas of the battlefield, NPS is compelled to

remove these structures and restore the historic scene. Partnerships with private entities and local and state governments will permit increased protection and interpretation of Civil War resources, as well as of historically significant viewsheds and roads outside of the park’s boundaries. Together, these actions will allow NPS to meet the legislative purposes of the park.

Specifically, under the selected action, NPS will rehabilitate both the significant large-scale and small-scale elements of the park’s historic landscape. NPS will reinstitute the pattern of open fields and wooded areas, and the historic circulation system of lanes, present during the battle. This will restore within the Battle Action Resource Area the fields of view that prevailed in 1863 and allow visitors to understand how the armies moved across the landscape. The selected action also includes within the Battle Action Resource Area the rehabilitation of those small-scale landscape elements–fences, woodlots, orchards and other features–that were significant to the outcome of the battle. The selected action will enable visitors to appreciate the obstacles and terrain that confronted individual troops during the conflict.

The selected action will rehabilitate the major landscape features and circulation of the Civil War portion of the Soldiers’ National Cemetery, as well as its significant design features. Together these actions will allow visitors to understand the equality of sacrifice made by those who lost their life in the battle, as intended by the designer of the Soldiers' National Cemetery.

The selected action will also restore the major features of the park’s Battlefield Commemorative Area, including monument groups. The selected action will provide for enhanced protection of these resources, which are the most threatened by visitor overuse. It will incorporate coordinated measures to manage visitor use and transportation, including a shuttle to provide access to park sites and a link to downtown. This will respond to visitor desires to see the battlefield while protecting sensitive cultural and natural resources from damage. The selected action will also revise agricultural practices in order to protect historic and natural resources through such means as altering mowing schedules to protect nesting birds, removing wetlands and streambanks from pastures, utilizing low-till and no-till methods, and limiting pesticide use. (Historic field patterns will be recreated by erecting fences or hedgerows in existing historic crop fields and in newly opened areas.)

The Visitor Center and Cyclorama Building are currently located on some of the Battle of Gettysburg’s most historically significant land along Cemetery Ridge, known as Ziegler’s Grove. Ziegler’s Grove was at the center of the Union line during the second and third days of the battle, and was the site where more than 6500 men fought. To achieve the park’s legislative mandate park managers determined to return Ziegler’s Grove to its 1863 appearance by removing the intrusive Visitor Center and Cyclorama Building. The relocation of visitor facilities to a new site near their existing location but on land that was not significant to the outcome of the battle will allow restoration of Ziegler’s Grove, the area that was the center of the Union Line during the second and third days of the battle.

The selected action will include measures to interpret the role of both soldiers and noncombatants, and will strengthen the interpretation of the role of the town of Gettysburg in the battle and its aftermath and link it to the battlefield. It will expand partnerships and cooperative initiatives with entities at all levels, especially those that could protect the historically agricultural character of significant battle and Civil War sites outside the park’s boundary, the character of historic road corridors and park gateways, and important park viewsheds.

The approach to rehabilitation incorporated in the selected action will broaden the scope of overall interpretation and expand the number of venues that could be well understood by and interpreted to visitors. In turn, the opening of new sites for interpretation will provide relief for heavily visited and adversely impacted sites. The selected action also adopts a previously approved Development Concept Plan/Environmental Assessment, which proposed consolidation of park offices and visitor facilities not included in the park’s museum and visitor center to a site within the Visitor and Park Services Overlay Area.

Alternative C, the proposed plan in the Final GMP/EIS and the selected action, provides the most desirable combination of resource preservation, visitor interpretation and experience, and cost-effectiveness among the alternatives considered for meeting the legislative purposes and mission of Gettysburg NMP. The selected action will allow NPS fully to meet both its resource preservation and interpretive mandates.

The selected action will significantly improve resource protection. The selected action will preserve and rehabilitate the features that were significant to the outcome of the battle and allow the restoration of Ziegler’s Grove, the site of some of the most intense and bloodiest fighting of the war. It will significantly enhance preservation and rehabilitation of the nationally significant Soldiers' National Cemetery, the site of Lincoln’s Gettysburg Address and of the burial of many Union dead. It will preserve the nationally significant commemorative corridors of Gettysburg NMP by providing for the restoration of monument groups (markers, monuments, cannon, etc.) and by limiting future damage from visitor overuse to sensitive resources here. Transportation management will further protect sensitive resources from vehicular damage. New collections storage will provide adequate conditions for the preservation and curation of the park’s collections and archives. A new, environmentally stable gallery in which the conserved cyclorama painting will be displayed will allow NPS to stem further deterioration and adequately preserve this National Historic Object.

Changes in the management of the park’s agricultural program to enhance surface water quality in the park’s streams and ponds, enhance streambank stabilization and reduce soil erosion will protect watershed areas considered significant to the Chesapeake Bay. The combination of removal of non-historic woodlands and changes in the agricultural tilling, mowing and haying techniques will allow NPS to better protect the state-listed open-land species that inhabit the park.

In addition, the selected action will encourage partnerships with private entities and local and regional governments to protect, preserve and interpret resources that are related to the Battle of Gettysburg, its aftermath and commemoration that are located outside of park boundaries. The selected action calls for partnership actions to preserve resources and interpret the role of the Borough of Gettysburg in the battle, its aftermath and the ongoing preservation of the battlefield. It also encourages partnerships with private

entities and local and regional governments to protect the agricultural setting of the park and major roadways leading to the park, including Taneytown Road and Baltimore Pike, elements that are important to a visitor’s experience. These actions should limit somewhat the amount of significant battle and Civil Wars sites outside the park boundary lost to commercial and suburban development.

The selected action also will greatly improve interpretation of the Battle of Gettysburg, its aftermath and commemoration both through enhanced museum interpretation as well as through landscape restoration. New museum exhibits will provide substantially improved interpretation of the battle in its full context, as required by the park’s legislation. Visitors’ experiences in the park will be improved, both in the museum complex and on the battlefield. Visitors will receive improved orientation and information about how to use the park. Rehabilitation of the landscape will allow visitors to understand both the movements of the armies as well as the impact of the battle on individual soldiers. Rehabilitation of the Soldiers' National Cemetery will allow visitors to understand the meaning inherent in its design, a meaning so eloquently defined by Abraham Lincoln in the Gettysburg Address.

Implementation of this action will increase visitation and length of stay at the park, which in turn will increase per capita spending by 10% over current levels. The combination of higher per capita spending and a moderate increase in visitation means that visitors will spend an additional $24,278,900 annually in the communities adjacent to the park, an increase of 21.5% over current spending levels. (Final GMP/EIS, 91-92, 282-286)

The Final General Management Plan / Environmental Impact Statement describes four alternatives for management, the environment that will be affected by those alternatives, and the environmental consequences of implementing these action alternatives. The major topic areas covered in each alternative are related to the park’s four mission goals, and include resource protection and rehabilitation, visitor interpretation, visitor experience, and partnerships. Major impact topics include impacts to cultural resources, impacts to natural resources, impacts to visitor interpretation and experience, impacts to the socio-economic environment, impacts to traffic, parking and transit, and impacts to park operations.

NPS considered three alternatives in addition to Alternative C, the proposed plan. They are:

Alternative A: Continuation of Current Management

This alternative assumed continuation of current policies and associated actions. It provided a baseline for comparison of the other alternatives and is required by the National Environmental Policy Act regulations. Alternative A retained the management guidance and direction of the 1982 General Management Plan and the subsequent Management Objectives developed in the 1988 Statement for Management. This alternative retained the management zones defined by the 1982 GMP and would have continued the management policies articulated in that document towards the landscape, park facilities, and visitor use management. Under this management strategy, NPS would have continued to preserve existing features and resources significant to the battle. Existing historic cropfields and woodlots would have continued to be preserved and maintained in their current conditions, using contemporary agricultural techniques. The Soldiers’ National Cemetery would have continued to be managed to maintain and perpetuate modern vegetation and changes made for maintenance with modern equipment. In the commemorative area, individual monuments and monument groups would have continued to be preserved and restored, and the formal designed corridor in which the War Department placed them would have been recalled by mowing of the area. Modern features, such as parking areas, bollards, paths, fencing or other restraints would have been added as needed to protect resources from overuse and damage by pedestrians and vehicles. NPS would have continued to manage Big Round Top as a natural area. NPS managers rejected this option among other reasons because it failed to provide adequate protection to the park’s three historic landscapes, did not allow for the restoration of Ziegler’s Grove, and did not provide adequate protection for the park’s archives, collections and the cyclorama painting. For a fuller discussion of the issues surrounding a continuation of current management policies, see the discussion of issues considered on pages 10-17 of the Final GMP/EIS.

This alternative included the least costly set of actions that would have responded minimally to the park’s mission goals. Alternative B incorporated rehabilitation of large-scale landscape features in the Major Battle Action Area and the Soldiers’ National Cemetery and preservation of other 1863 features. It would also have provided a new museum complex to replace obsolete facilities and meet the park’s interpretive goals. Because the actions included in Alternative B were considered necessary to meet minimally the park’s mission goals, the actions recommended in this alternative were also incorporated into Alternative C, the selected action, and Alternative D.

As a part of Alternative B, the rehabilitation of large-scale landscape features would have reinstated the patterns of open and wooded areas within the Major Battle Action Area, including restoration of Ziegler’s Grove. Because of this action, NPS would be able to represent accurately the patterns of open land vs. forested land present during the battle in the areas where major battle action occurred. This would allow visitors to visualize and understand the major movements of the armies and to appreciate tactical decisions made by its leaders. Alternative B would not, however, have rehabilitated the small-scale features that were significant to the outcome of the battle, such as fence lines or orchards.

Alternative B also suggested rehabilitation of the large-scale landscape and designed features that characterize the Saunders design for the Soldiers’ National Cemetery. Under this alternative, the cemetery would have remained in its modern condition, except that the vegetation and circulation in the Civil-War portion of the cemetery would have been managed so that visitors could understand the ideas of equality expressed by Saunders in the design. These ideas parallel those expressed by Abraham Lincoln in his Gettysburg Address. The commemorative landscape would have been managed similarly to Alternative A.

This alternative incorporated the development of a new museum complex and associated facilities that could provide improved interpretation and visitor services, located on a site that was not pivotal to the outcome of the battle. Enhanced programs would have provided broad, in-depth interpretation of the causes and consequences of the Gettysburg Campaign, its impact on participants and noncombatants, and the enduring meaning of the Gettysburg Address. Strong linkages would have been provided from the park and the proposed museum complex to historic structures at the center of the Borough of Gettysburg. NPS would have worked cooperatively with partners to communicate the role of key in-town sites during and after the battle. Based on such agreements, an NPS presence would have been possible to interpret these topics.

The broad initiatives of this alternative would have improved the visitors’ understanding of the battle landscape by making it possible for them to understand the movements of the armies – the generals’ perspective – and by providing greatly improved centralized interpretation of the causes and consequences of the Gettysburg Campaign. Alternative B also incorporated visitor activity management policies that would have improved the condition of park resources by limiting damage from visitor use.

This alternative provided for better protection of the park’s landscape and historic resources than did Alternative A, no action. However, NPS managers rejected this option because they considered that the rehabilitation of both the large-scale features and the small-scale features that were significant to the outcome of the Battle of Gettysburg, its aftermath and commemoration (as called for in Alternative C, the selected action) would more fully meet the park’s legislative mandates by preserving and rehabilitating all features that were significant to the outcome of the battle. In addition, although Alternative B would have improved interpretation of the battlefield, especially of the general’s perspective, the selected action would allow visitors to understand not only the general’s perspective but also the impact of the battle upon individual combatants and civilians.

This alternative included the resource management, interpretive and museum facilities actions included in Alternative C. However, Alternative D expanded on the resource management actions described in Alternative C by recommending additional rehabilitation and restoration. Alternative D proposed restoring the entirety of the known and documented battle landscape in the Major Battle Action area and the significant elements outside the Major Battle Action area included in the other resources area. This alternative would have rehabilitated all identifiable historic features, regardless of their significance to the outcome of the Battle of Gettysburg.

Rehabilitation of missing features from the commemorative era, principally along the system of commemorative avenues, would have allowed visitors to experience the commemorative park built by battle veterans. Interpretation would have relied heavily on the new museum complex to provide the context overview, and assumed that visitors would be able to understand those stories without extensive field interpretation because NPS had fully restored the battlefield, cemetery and commemorative landscapes.

Modern wayside signs would have been removed and visitors would have had to rely on the system of markers placed by the park’s veterans to understand and experience the park. Visitors would have been encouraged to concentrate their travel along the commemorative avenues, and alternative means of transport and interpretation would have encouraged visitors to tour the battlefield with far less reliance on private vehicles than currently.

Although this alternative provides for better protection of the park’s landscape and historic resources than Alternative A, and for more extensive rehabilitation than either Alternative B or C, NPS managers rejected it because the environmental and dollar costs were much greater than any other alternative because it proposed rehabilitation of the entire park, including places that were not the site of major battle action. In addition, NPS managers did not consider that this alternative could provide significantly improved resource protection or interpretation.

In addition, a number of other alternatives were considered by the planning team or in public workshops, but not included for further consideration in the Draft GMP/EIS. These are discussed in detail on pages 58-60 of the Final GMP/EIS.

Two additional alternatives were proposed and reviewed with the public in workshops and were presented in GMP newsletters. These alternatives were called Improve Areas of Most Intensive Use, and Diversified Visitor Experience. The first recommended traffic free zones representing each day of the battle, where special interpretation, resource protection and other actions would occur. The public generally felt that this approach was too restrictive and placed too much emphasis on first time visitors. The second alternative placed its emphasis on innovative interpretation of the battlefield. NPS would have concentrated its resources on interpretation rather than on rehabilitation and restoration, although a minimum level of rehabilitation of the park’s landscapes was included. Most participants liked the idea of expanded interpretation, but believed it should be combined with the higher levels of rehabilitation and preservation proposed by the other alternatives.

The GMP team considered two other alternatives, Full Restoration and Interpretation Only. The first responded to the perception among some participants in the public process that the battlefield should be fully restored to its 1863 condition. However, NPS determined that this was not feasible and would not comply with the Secretary’s Standards for Historic Preservation because of its impact on the park’s two nationally significant post-battle landscapes, the Soldiers' National Cemetery and the commemoration built by battle veterans. The Interpretation Only alternative would have included no rehabilitation and restoration of park features. However, visitor surveys, comment during scoping, and experience with visitors on the site convinced NPS managers that this approach could not meet the park’s interpretive goals. In addition, NPS managers believed that this approach would not allow NPS to meet its legislative purposes. For these reasons, these four alternatives were eliminated from further consideration.

NPS’ consideration of alternatives for its visitor facilities, through the development of the draft DCP and its RFP process is discussed in the Background of the Project section of this ROD.

The environmentally preferred alternative is defined as "the one that will promote National Environmental Policy as expressed in the National Environmental Policy Act’s, section 101. Ordinarily, this means the alternative that causes the least damage to the biological and physical environment; it also means the alternative which best protects, preserves, and enhances the historic, cultural, and natural resources in the area where the proposed action is to take place." ("Forty Most Asked Questions Concerning Council on Environmental Quality’s (CEQ) National Environmental Policy Act Regulations," 1981).

The environmentally preferred alternative is Alternative C, the selected action. Alternative C best protects, preserves and enhances the historic, cultural and natural resources of Gettysburg NMP. In particular, the selected action: increases the ability of the park to protect, preserve and enhance the historic and cultural resources of the park and meet its legislative mandate; minimizes the loss of forest cover while achieving the park’s critical cultural resource goals; improves the capability of the park’s natural environment to support the state-listed open land species; and allows NPS to meet more fully the requirements of the Chesapeake Bay Program.

As noted above, the selected action improves the ability of NPS to protect the essential resources of Gettysburg NMP. Through this proposal, NPS could: preserve and rehabilitate the resources considered significant to the outcome of the battle; protect the cyclorama painting, collections, and archives; and preserve and rehabilitate the significant features of the Soldiers' National Cemetery and commemorative landscapes of the park. The selected action allows NPS fully to meet the requirements of Gettysburg NMP’s legislation at the least cost to the environment, park visitors and the Federal budget. The provision of new museum facilities on a site removed from the park’s most important resources means that NPS could restore these significant areas. Although the new construction needed to consolidate the park’s museum and visitor facilities would permanently remove 18 acres of land, including up to 2 acres of wetlands, at the new site as wildlife habitat, NPS will be able to restore about 38 acres of meadow, orchard and woodlands that were very significant to the outcome of the battle at the sites of the current facilities.

Alternative A, as described in the Final General Management Plan / Environmental Impact Statement, does not provide adequate protection for the park’s three historic landscapes, its cultural and natural resources, or its collections, archives and the cyclorama painting and therefore does not meet the park’s legislative mandate.

Alternative B, as described in the Final General Management Plan / Environmental Impact Statement, would provide many of the same cultural and natural resource benefits as described in the selected action. Both alternatives would include the rehabilitation of the pattern of open vs. closed areas present during the battle, actions to preserve resources in the Soldiers' National Cemetery and the commemorative Resource Area, reformulation of the park’s agriculture program, and provision of new visitor facilities. However, Alternative C, the selected action, more fully meets NPS’ legislative purposes because it provides for the protection and, where needed, the rehabilitation, of all features that were significant to the outcome of the Battle of Gettysburg, its aftermath and commemoration. Alternative B merely provides for the rehabilitation of a subset of those resources during the period of the plan.

Alternative D, as described in the Final General Management Plan / Environmental Impact Statement provides for maximum rehabilitation of the park’s landscapes, including all features that could be documented. This would provide for rehabilitation of landscapes and features beyond that called for by the park’s legislative purposes. Although this could provide a more complete experience of the conditions prevalent in 1863, the environmental costs would be concomitantly greater. Because park managers do not consider that additional restoration would significantly improve interpretation or protection of essential resources, the additional environmental costs would not be warranted.

The selected action provides the appropriate balance between protection and rehabilitation of the park’s significant cultural and natural resources and environmental costs.

NPS has identified and incorporated into the selected action all practical measures to avoid or minimize environmental impacts that could result from its implementation. These measures are presented in detail in the Final General Management Plan / Environmental Impact Statement.

Rehabilitation of the features that were significant to the outcome of the Battle of Gettysburg, its aftermath and commemoration has the potential to cause environmental harm. NPS will take the following actions to avoid or minimize harm resulting from these actions:

• Impacts to known and unknown archeological resources due to tree removal will be mitigated and minimized by implementing Section 106 of NHPA, through the use of best management practices, and through appropriate design that will allow for little ground disturbance.
• Use of best management practices will minimize impacts to topography due to tree removal and existing roads and lanes will be used so that no new roads will need to be constructed.
• Short-term impacts to soils due to tree removal will be minimized using best management practices.
• Tree removal may have an impact to roosting and nesting areas of black vultures in the park. These actions will be mitigated by leaving the white-pine trees typically used by vultures and by leaving small clumps and mature trees around known nesting areas.
• Tree removal may have an impact on certain species of the fauna of the park. None of these species are rare or of special concern. However, NPS will minimize these impacts by using best practices and by monitoring of specific taxa.
• Localized steam water temperature will increase in some sub-watersheds from loss of forest cover; however, this can be minimized by planting low growing woody vegetation along stream corridors.
• Tree removal and conversion of the area into an actively managed woodlot could have an impact on one state-listed plant specie. However, using best management practices for tree removal and protecting individual plants could minimize this. Maintaining the area as a woodlot will benefit the plant by opening the canopy.

Rehabilitation of Ziegler’s Grove and the center of the Union’s battle line along Cemetery Ridge necessitates the removal of the Cyclorama Building, which is listed on the National Register of Historic Places. In December 1998, NPS began consultations with the Advisory Council on Historic Preservation, the Pennsylvania Historic Preservation Officer, and interested parties and individuals regarding the removal of the structure. On May 14, 1999, the Advisory Council on Historic Preservation concurred with the draft GMP/EIS’ proposed restoration of the park’s historic landscapes and the cyclorama painting, and the removal of the Cyclorama Building, finding that "The rehabilitation of this key battlefield site so that the battlefield can properly be interpreted must be regarded as a historic mission of the highest order." A history of related actions is included on page 241 of the Final General Management Plan / Environmental Impact Statement; the Advisory Council on Historic Preservation’s Finding is included as Appendix 11. After that decision, NPS consulted with the Advisory Council, the Pennsylvania State Preservation Officer and interested parties to develop appropriate mitigation policies with regard to the removal of the Cyclorama Building and in accordance with the Memorandum of Agreement dated July 29, 1999.

Construction activities related to the relocation of the park’s museum complex, visitor facilities and administrative facilities to a site removed from its prime resources have the potential to cause environmental harm. NPS will take the following actions to avoid or minimize harm resulting from these actions:

• Implementation of appropriate erosion control and revegetation measures will minimize short- and long-term disturbance and vegetation loss from construction activities for the new visitor facilities, administrative facilities, burial of utility lines, and other actions.
• Unknown archeological resources may be impacted by development activities and, if significant, the facilities will be relocated or the archeological resources could be excavated to salvage the artifacts. In addition, a monitoring and preservation program will allow archeologists to determine the nature of cumulative impacts, and devise avoidance or mitigation methods.
• Two small areas of historic rock walls may be destroyed to accommodate entrances to the new museum complex. NPS will consult with the Advisory Council and the State Historic Preservation Officer to develop appropriate mitigation policies with regard to the removal of these two sections of wall.
• Design of the new visitor or administrative facilities will seek to minimize topographic changes and keep as much of the new site in a natural condition as possible.
• Approximately 10 acres of prime farmland may be impacted by development; a Farm Conversion Impact Rating and Land Evaluation System Report will be completed before any work begins. Approximately 38 acres of meadow, orchard, and woodlands will be re-established at the sites of the old visitor centers to mitigate the removal of approximately 21-26 acres of hay and 8 acres of woods at the new museum and visitor center site.
• Up to 2 acres of wetlands could be impacted due to construction; however, a Wetlands Statement of Findings as required by Directors Order 77.1, will be completed prior to the initiation of work. In addition, up 100 acres of wetlands will be restored as a result of changes to the agriculture program and the removal of field drains in agricultural fields.
• Construction activities could temporarily displace or kill some individual wildlife or flora around the new visitor and administrative facilities. This will be mitigated through the park’s inventorying and monitoring program to assure no sensitive species are being affected.
• Visitors might be temporarily inconvenienced by construction and relocation activities; however, construction and relocation will be scheduled to avoid the peak visitation periods.

Although overall visitor spending will increase due to the new museum complex, redistribution of visitor spending may occur because of the relocation of the museum complex. The anticipated increases in visitation, the increase in length of stay, the limitation of the menu and of the serving times in thefood service facility, the routing of the park auto tour route through the Borough of Gettysburg, and the continued availability of information about community visitor facilities in the museum by the Visitor and Convention Bureau should help mitigate these impacts. To minimize development of new tourism related private development near the new museum site, NPS, either directly or through its various partners, will protect through easement or acquisition, lands that were significant to the outcome of the Battle.

NPS officially began the EIS process on May 5, 1997 with the publication in the Federal Register of a Notice of Intent to prepare a draft EIS. Scoping meetings were held to identify issues and concerns relating to the proposed general management plan. As a part of its scoping for the EIS, Gettysburg NMP requested public and agency review the park’s legislative purposes, mission, and mission goals, developed as a part of NPS’ compliance with the Government Performance and Results Act. NPS also held meetings to discuss its analysis of park resources, concepts for the park, and alternatives for the park. After NPS selected a proposal for negotiation for new museum and visitor facilities (as a result of the Draft Development Concept Plan and Environmental Assessment for Collections Storage, Museum and Visitor Facilities and subsequent RFP), it held additional meetings to review the details of the proposed facilities and their possible environmental consequences with the public. During Spring, 1998, NPS determined as a result of these meetings and other agency and public comment to combine the Draft Development Concept Plan and Environmental Assessment for Collections Storage, Museum and Visitor Facilities with the ongoing GMP/EIS process. During this period, NPS also prepared and mailed five newsletters to interested agencies, organizations, and individuals.

A Draft General Management Plan / Environmental Impact Statement was developed and released to the public on August 14, 1998. Almost 3,800 copies of the Draft General Management Plan / Environmental Impact Statement were distributed to agencies, organizations and the public. The Notice of Availability of the draft EIS was published in the Federal Register on August 18, 1998. Nine public meetings were held during the public comment period. Two workshops provided an overview of the entire GMP. Four workshops concentrated on a particular aspect of the plan, including resource preservation and rehabilitation, socioeconomic impacts, partnership issues including traffic, and interpretation and education. One meeting held by the Gettysburg NMP Advisory Commission, incorporated discussion on the GMP and the museum complex proposal. All seven of these meetings included question and answer sessions. NPS also held two formal public hearings to allow the public to comment on the plan. A listing of meetings, public workshops and hearings, and consultation activities is included in the Final General Management Plan / Environmental Impact Statement beginning on page 306.

The comment period on the draft ended October 17, 1998. Between October 1998 and May 1999 NPS met with local governments, members of Congress and representatives of state and local agencies and organizations to ensure that their comments and concerns had been properly understood. Comments received through January 20, 1999 were included in the Final GMP/EIS.

NPS received over 500 oral or written comments on the draft GMP/EIS. Some comments concerned the relocation of the park’s visitor centers to a nearby site. Some commentors, representing descendents of the more than 6500 men who fought where the Visitor Center and Cyclorama Building are now located, contended that appropriate restoration of the Ziegler’s Grove area is necessary because of the approximately 970 soldiers who became casualties of the Battle of Gettysburg at that location. Others, many of whom operate businesses in close proximity to the park’s visitor centers, are concerned that NPS’ relocation of its visitor facilities would impact their businesses, either by changing pedestrian patterns or by removing parking from near their businesses.

NPS acknowledged in the draft GMP/EIS that despite the overall positive economic impact resulting from Alternative C, the selected action, the relocation of park visitor facilities might change visitor spending patterns and create indirect effects on area development or individual businesses. Because of comments received during scoping, NPS had included actions to mitigate possible effects in the draft GMP/EIS. These included: NPS partnership in the development of the Wills House; an NPS ranger presence in downtown; partnerships to strengthen the historic pathways pedestrian environment; expansion of NPS’ auto tour to include resources within the Borough of Gettysburg; inclusion of a downtown/park shuttle; protecting sites within the park boundary and the Gettysburg Battlefield Historic District from inappropriate development; and continued promotion of local visitor services by the Visitor and Convention Bureau in the park visitor center. As a result of comments received on the draft GMP/EIS, NPS enhanced its discussion of the protection of Taneytown Road and Baltimore Pike, and included capital costs for the shuttle, which had inadvertently been left out of the draft GMP/EIS. Finally, NPS decided to provide parking to serve the Soldiers' National Cemetery near the existing parking lots and included this in the Final GMP/EIS.

Other commentors were concerned that the inclusion of a cafeteria-style restaurant, arts and crafts store and other retail activities originally proposed for inclusion in the museum complex would compete unfairly with local businesses. One of NPS’ goals was to improve visitors’ experiences in the museum complex by providing necessary and appropriate facilities that would enable them to extend their stay in the facility and properly use and enjoy the facility. During GMP scoping, NPS evaluated the proposal in relation to this goal, and determined what was necessary and appropriate to allow visitors to extend their stay in the facility and therefore in the community. Because of this scoping process, NPS reduced the size of the cafeteria-style restaurant and eliminated the arts and crafts store and other retail activities in the proposed new museum complex. These changes were described in the draft GMP/EIS.

However, even after making these changes in the draft GMP/EIS, NPS received comments about the food service facility during the public review of that document. After a review of the comments received on the draft GMP/EIS, NPS reevaluated its needs again and determined that it could further reduce the scope of the food service to be included in the facility and still meet its goal. NPS determined that limited food service would allow visitors to extend their stay and properly use and enjoy the facilities. Therefore, NPS decided to change the cafeteria-style restaurant to a limited food service facility, operating with a warming kitchen and providing snacks and light meals only. An economic assessment performed on this limited food service option found that food service expenditures within the park would decrease by 34% from the level predicted in the draft GMP/EIS, and that visitor expenditures outside the park would therefore increase by an estimated additional $495,000 per year, to a total of $24,278,900 annually. This represents an increase in visitor spending of 21.5% over current spending levels (Final GMP/EIS, pages 91-92, 282-286).

Some commentors feared that the new museum complex would commercialize the battlefield. However, NPS considers that the proposed collections storage, museum and visitor facilities do not commercialize the battlefield, but provide necessary and appropriate services to visitors that enhance the visitor experience and are entirely consistent with NPS policies, regulations and statutes. The existing visitor facilities at Gettysburg NMP include collections storage, a museum, a visitor center, the electric map, the cyclorama painting, a conventional theater in which NPS presents an education film, a licensed battlefield guide tour center, and the park’s book and museum store. The new facility will continue these uses, providing enough space to make these operations more efficient. The new facility will also provide limited food service. The new facilities will allow NPS to provide superior orientation and interpretation, adequate protection for its collections, archives and the cyclorama painting, and will remove modern intrusions from the historic core of the battlefield.

Others were concerned that the inclusion of the museum proposal as a part of the GMP/EIS violated NPS policy or NEPA. However, after considering public and agency comment on the issue, NPS determined that it was in the public interest to combine the two ongoing public processes into the GMP/EIS. NPS considers that the environmental review procedures followed in this matter, including consideration of public comment as a part of the process, complied with NEPA.

Finally, some commentors are concerned that net removal of 576 acres of non-historic woodlands would create environmental impacts on local plant and animal communities and that rehabilitation of the battlefield was not necessary for proper interpretation of the battlefield. NPS determined that it could best meet its legislated purposes and mission, and provide a more meaningful visitor experience, by rehabilitating the battlefield in the manner described in the selected action. NPS acknowledged that removal of non-historic woodlands would have an impact on some forest species. However, with the exception of the black vulture, these species are widespread and the removal of non-historic woodlands would not affect their abundance or distribution. NPS considers that impacts upon the state-listed black vulture could be mitigated by the activities noted in the previous section. As noted above, the concomitant increase in meadow and pasture land will increase and improve open-land habitat and therefore the sensitive state-listed species that depend upon that habitat.

NPS responded to substantive comments in the final EIS, which was released to the public on June 18, 1999. NPS mailed approximately 586 copies of the two-volume document to agency, organizational and individual commentors. The Notice of Availability of the final EIS appeared in the Federal Register on June 25, 1999, and the Final General Management Plan / Environmental Impact Statement was made available for a 30-day no action period starting on that date.

In accordance with the Programmatic Agreement among the National Park Service, the Advisory Council on Historic Preservation and the National Conference of State Historic Preservation Officers executed July 17, 1995, NPS has completed the consultation review steps related to general management planning (VI. C., D., and E.). NPS, the Pennsylvania State Historic Preservation Officer and the Advisory Council on Historic Preservation have negotiated and on July 28, 1999 signed a Programmatic Agreement. Implementation of this agreement will fulfill the NPS’ responsibilities under Section 106 of the National Historic Preservation Act.

Letters received from the Pennsylvania Natural Diversity Inventory of the Pennsylvania Department of Conservation and Natural Resources and the U.S. Fish and Wildlife Service are included as Appendix 7 of the Final General Management Plan /Environmental Impact Statement. These letters identified threatened, rare and endangered species and species of special concern protected by the respective agencies. There are no known Federal threatened, rare and endangered species within the park. Impacts to state listed species are either positive, or can be mitigated, as noted above.

The public and agency comments contained in the two volumes of the Final General Management Plan / Environmental Impact Statement and additional information available in the files at Gettysburg NMP headquarters provides valuable background for the context in which the proposed plan has been developed. All comments received on the Draft and Final General Management Plan / Environmental Impact Statement are on file at Gettysburg NMP headquarters in Gettysburg, Pennsylvania.

/s/ John A. Latschar 11/17/99

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Dr. John A. Latschar, Superintendent

Gettysburg National Military Park
National Park Service

/s/ Marie Rust 11/23/99

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Marie Rust, Regional Director

Northeast Region

National Park Service