Letter: Memo of agreement does not reflect Trust’s view


The Navy has determined that expansion of the Growler operations at Naval Air Station Whidbey Island will have an adverse effect on the Central Whidbey Island Historic District, Ebey’s Landing National Historical Reserve.

As part of the Navy’s consultation process, they released for public comment a draft Memorandum of Agreement outlining a plan to mitigate the adverse effect on historic properties in accordance with Section 106 of the National Historic Preservation Act.

The Trust Board of Ebey’s Landing National Historical Reserve would like to clarify that, while they are involved in the consultation, the draft Memorandum of Agreement does not reflect the trust board’s view of mitigation for the adverse effect.

Throughout the consultation process, the trust board has remained unchanged in its view that, because noise is the cause of the adverse effect, the only way to resolve or mitigate the adverse effect is to reduce the increase in noise that this undertaking will bring.

However, because the focus of Section 106 review process is limited to historic properties, the trust board has participated in consultation to discuss ways to avoid, minimize or mitigate adverse effects to the historic district, i.e., the reserve.

The trust board’s view is that the reserve was established because the public strongly sought protection for this area and its unbroken, ongoing history. Therefore, the trust board believes mitigation should benefit the public and focus on historic properties that are valued by the public and open to public access and oversight.

The trust board also believes that mitigation should reflect the local, multi-partner stewardship of the reserve. This means local partners, who set priorities for preservation in the reserve, should make the determination of where mitigation should be focused.

While mitigation is likely to involve funding, the trust board is less concerned with amounts of funding needed to accomplish mitigation.

The main concerns of board members are that mitigation achieves a clear public benefit, reflects local preservation priorities, and reinforces the partnership model that was established to protect the nation’s first National Historical Reserve.

Kristen Griffin, reserve manager

Trust Board of Ebey’s Landing National Historical Reserve

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