Protect Gettysburg battlefield structures from demolition
Demolition/Removal of Select Assets
National Park Service· Gettysburg National Military ParkNPS Planning (PEPC) project page ↗
NPS PEPCWe track this on the agency’s own system of record, where most on-the-ground decisions live.
The groups on this fight
4 groups work Pennsylvania
By footprint, from the same match the STAND matchmaker runs; none is linked to this decision in our record yet. Give straight to them; nothing routes through us.
- Center for Biological Diversity
Works Pennsylvania: fighting the current logging surge on the Allegheny as a threat to endangered bats and hellbenders.
- Environment America
Works Pennsylvania: its Pennsylvania arm documented the forest's exposure to logging and gas drilling in a dedicated report.
- Gettysburg Foundation
Works Pennsylvania: they work only in Pennsylvania.
- Sierra Club
Works Pennsylvania: longtime co-plaintiff in litigation against Forest Service timber projects on the Allegheny, including the East Side clearcutting case.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The Park Service may demolish historic assets at Gettysburg National Military Park, a nationally significant Civil War battlefield.
What’s at risk
Historic structures, landscapes, or infrastructure at Gettysburg National Military Park could be permanently lost. The park is drafting an agreement that would govern how historic preservation responsibilities are handled during demolition and removal work.
If this goes through
If approved, select assets at Gettysburg would be demolished or removed, potentially destroying irreplaceable historic fabric at one of the country's most important Civil War sites.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
8 holes in the agency’s own analysis
What the public could have raised, from the agency’s own document
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The document's title is 'Demolition/Removal of Select Assets,' but the underlying HSAR recommends preservation and rehabilitation, not demolition. The HSAR explicitly states that 'Rehabilitation is the recommended ultimate treatment and use for the building' and calls for removal only of three non-historic additions. There is a direct contradiction between the decision document's framing as a demolition action and the HSAR's conclusion that the historic barn core should be preserved. The agency must reconcile this contradiction by explaining which specific assets it proposes to demolish, why demolition of any contributing National Register element is warranted, and how that decision complies with Section 106 of the National Historic Preservation Act.
- The barn is a contributing structure to a National Register district accepted in 2004, yet the document never demonstrates that a Section 106 consultation was completed or that the Advisory Council on Historic Preservation was notified before a demolition or removal decision was made. Chapter 5 acknowledges the requirements of 'the National Historic Preservation Act (Section 106, Section 110, and ACHP)' but provides no evidence that those consultations occurred or that a finding of effect was issued. The agency must release any Section 106 consultation records, finding of adverse effect determination, and memorandum of agreement before proceeding.
- The HSAR rates the barn's overall condition as POOR/SERIOUS, not as failed or irreparable. The document's own condition table shows that the historic barn core bents, rafters, interior forebay wall, summer beam, sills, and joists all rate FAIR/MINOR, meaning they need only routine monitoring. Selecting demolition or removal of any portion of the historic core while the HSAR recommends preservation and mothballing is an unreasoned leap. The agency must explain, with engineering data, why a POOR/SERIOUS overall rating justifies removal rather than the stabilization the HSAR itself prescribes.
- The lightning protection system is rated POOR/CRITICAL, with severed downlead cables rendering it nonfunctional, and the barn has no fire extinguishers, smoke detectors, or fire detection system. The HSAR flags these as immediate life-safety issues and cites Director's Order 58 requiring safeguards against catastrophic loss. Yet no fire-risk analysis quantifying the probability or consequence of fire to this National Register structure is provided. If a fire destroys the barn before stabilization, the loss is irreversible. The agency must provide a fire-risk analysis and confirm that immediate fire-safety measures will be in place before any other work is deferred.
Show all 10 points from the document
- Section G9087 warns that once the non-historic south and east additions are removed, neutral drainage on three elevations 'could retain water at the base of the barn,' worsening the already-documented deterioration of foundations and the bulging retaining wall. The removal of additions is listed as a contract task in the programming estimate, but the drainage remediation plan is described only vaguely as 'minor re-grading.' No engineering study or drainage design is cited to confirm that removal of additions will not accelerate structural failure. The agency must require a site drainage engineering study before addition removal begins and incorporate approved drainage improvements as a concurrent scope item, not an afterthought.
- The HSAR identifies a hazardous materials survey as a necessary preliminary step before any work in the building, noting that lead-based paint and asbestos-containing materials are the two most common hazards in historic buildings. The programming estimate and scope of work in Chapter 5 list demolition of the garage, milking parlor, and loading shed as a contract task, but no hazardous materials survey results are cited anywhere in the document. Demolition without a prior hazmat clearance exposes workers and the public to lead and asbestos. The agency must complete and disclose a hazardous materials survey before any demolition contract is awarded.
- The programming estimate carries a stated margin of negative 10 percent to positive 25 percent and totals $296,575, but it covers only stabilization tasks and explicitly excludes windows, doors, archaeological monitoring, and compliance costs, which are listed as the park's separate responsibility. No funding commitment or source is identified for the full rehabilitation phase that the HSAR recommends as the long-term treatment. Without confirmed funding, the barn may be stabilized at public expense and then left to deteriorate again, defeating the purpose of the investment. The agency must disclose the full lifecycle cost estimate including rehabilitation, identify the funding source and timeline, and explain what happens to the barn if rehabilitation funding does not materialize.
- The HSAR notes that the barn's west elevation timber-frame foundation wall is actively failing, with a center post tenon already displaced from its mortise and modern cribbing as the only thing preventing collapse, yet the recommended immediate treatment requires hiring a structural engineer to design new concrete footings before reconstruction can begin. No structural engineer's report is cited or attached. Proceeding with any work that disturbs adjacent foundations or removes supporting additions before that engineering design is complete could trigger sudden structural failure of the west wall and upper level. The agency must make the structural engineer's report public and confirm it has been incorporated into the work sequence before any contract is awarded.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
Section 106 Consultation and Supporting Docmentation
Did the agency answer?
15 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.
Issues on the record, awaiting the decision
- PendingThe document states three non-historic additions (loading shed, garage, milking parlor) currently obscure the historic bank barn core on the east and south elevations.
The document states three non-historic additions (loading shed, garage, milking parlor) currently obscure the historic bank barn core on the east and south elevations.
- PendingThe document states the stone retaining wall behind the barn's bank is bulging due to water intrusion from the lack of roof drainage.
The document states the stone retaining wall behind the barn's bank is bulging due to water intrusion from the lack of roof drainage.
- PendingThe document states the outshed granary's corrugated metal roof is missing panels on the east and west sides, allowing water into the structure.
The document states the outshed granary's corrugated metal roof is missing panels on the east and west sides, allowing water into the structure.
- PendingThe document states the barn's lightning protection system has severed, ungrounded downlead cables rendering it useless.
The document states the barn's lightning protection system has severed, ungrounded downlead cables rendering it useless.
- PendingThe document states there are no fire extinguishers, smoke detectors, sprinkler systems, or fire detection systems anywhere in the barn.
The document states there are no fire extinguishers, smoke detectors, sprinkler systems, or fire detection systems anywhere in the barn.
- PendingThe document states the barn is located approximately 1200 feet west of Emmitsburg Road and 0.8 miles from Eisenhower National Historic Site, with the EISE Show Barn and Seminary Ridge visible from th
The document states the barn is located approximately 1200 feet west of Emmitsburg Road and 0.8 miles from Eisenhower National Historic Site, with the EISE Show Barn and Seminary Ridge visible from the property.
- PendingThe document states the west exterior wall framing is structurally failing, with the center post tenon dislocated from its mortise due to compromised foundation and framing below, currently held by mo
The document states the west exterior wall framing is structurally failing, with the center post tenon dislocated from its mortise due to compromised foundation and framing below, currently held by modern cribbing.
- PendingThe document's title is 'Demolition/Removal of Select Assets,' but the underlying HSAR recommends preservation and rehabilitation, not demolition.
The document's title is 'Demolition/Removal of Select Assets,' but the underlying HSAR recommends preservation and rehabilitation, not demolition. The HSAR explicitly states that 'Rehabilitation is the recommended ultimate treatment and use for the building' and calls for removal only of three non-historic additions. There is a direct contradiction between the decision document's framing as a demolition action and the HSAR's conclusion that the historic barn core should be preserved. The agency must reconcile this contradiction by explaining which specific assets it proposes to demolish, why demolition of any contributing National Register element is warranted, and how that decision complies with Section 106 of the National Historic Preservation Act.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe barn is a contributing structure to a National Register district accepted in 2004, yet the document never demonstrates that a Section 106 consultation was completed or that the Advisory Council on
The barn is a contributing structure to a National Register district accepted in 2004, yet the document never demonstrates that a Section 106 consultation was completed or that the Advisory Council on Historic Preservation was notified before a demolition or removal decision was made. Chapter 5 acknowledges the requirements of 'the National Historic Preservation Act (Section 106, Section 110, and ACHP)' but provides no evidence that those consultations occurred or that a finding of effect was issued. The agency must release any Section 106 consultation records, finding of adverse effect determination, and memorandum of agreement before proceeding.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe HSAR rates the barn's overall condition as POOR/SERIOUS, not as failed or irreparable.
The HSAR rates the barn's overall condition as POOR/SERIOUS, not as failed or irreparable. The document's own condition table shows that the historic barn core bents, rafters, interior forebay wall, summer beam, sills, and joists all rate FAIR/MINOR, meaning they need only routine monitoring. Selecting demolition or removal of any portion of the historic core while the HSAR recommends preservation and mothballing is an unreasoned leap. The agency must explain, with engineering data, why a POOR/SERIOUS overall rating justifies removal rather than the stabilization the HSAR itself prescribes.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe lightning protection system is rated POOR/CRITICAL, with severed downlead cables rendering it nonfunctional, and the barn has no fire extinguishers, smoke detectors, or fire detection system.
The lightning protection system is rated POOR/CRITICAL, with severed downlead cables rendering it nonfunctional, and the barn has no fire extinguishers, smoke detectors, or fire detection system. The HSAR flags these as immediate life-safety issues and cites Director's Order 58 requiring safeguards against catastrophic loss. Yet no fire-risk analysis quantifying the probability or consequence of fire to this National Register structure is provided. If a fire destroys the barn before stabilization, the loss is irreversible. The agency must provide a fire-risk analysis and confirm that immediate fire-safety measures will be in place before any other work is deferred.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingSection G9087 warns that once the non-historic south and east additions are removed, neutral drainage on three elevations 'could retain water at the base of the barn,' worsening the already-documented
Section G9087 warns that once the non-historic south and east additions are removed, neutral drainage on three elevations 'could retain water at the base of the barn,' worsening the already-documented deterioration of foundations and the bulging retaining wall. The removal of additions is listed as a contract task in the programming estimate, but the drainage remediation plan is described only vaguely as 'minor re-grading.' No engineering study or drainage design is cited to confirm that removal of additions will not accelerate structural failure. The agency must require a site drainage engineering study before addition removal begins and incorporate approved drainage improvements as a concurrent scope item, not an afterthought.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe HSAR identifies a hazardous materials survey as a necessary preliminary step before any work in the building, noting that lead-based paint and asbestos-containing materials are the two most common
The HSAR identifies a hazardous materials survey as a necessary preliminary step before any work in the building, noting that lead-based paint and asbestos-containing materials are the two most common hazards in historic buildings. The programming estimate and scope of work in Chapter 5 list demolition of the garage, milking parlor, and loading shed as a contract task, but no hazardous materials survey results are cited anywhere in the document. Demolition without a prior hazmat clearance exposes workers and the public to lead and asbestos. The agency must complete and disclose a hazardous materials survey before any demolition contract is awarded.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe programming estimate carries a stated margin of negative 10 percent to positive 25 percent and totals $296,575, but it covers only stabilization tasks and explicitly excludes windows, doors, archa
The programming estimate carries a stated margin of negative 10 percent to positive 25 percent and totals $296,575, but it covers only stabilization tasks and explicitly excludes windows, doors, archaeological monitoring, and compliance costs, which are listed as the park's separate responsibility. No funding commitment or source is identified for the full rehabilitation phase that the HSAR recommends as the long-term treatment. Without confirmed funding, the barn may be stabilized at public expense and then left to deteriorate again, defeating the purpose of the investment. The agency must disclose the full lifecycle cost estimate including rehabilitation, identify the funding source and timeline, and explain what happens to the barn if rehabilitation funding does not materialize.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe HSAR notes that the barn's west elevation timber-frame foundation wall is actively failing, with a center post tenon already displaced from its mortise and modern cribbing as the only thing preven
The HSAR notes that the barn's west elevation timber-frame foundation wall is actively failing, with a center post tenon already displaced from its mortise and modern cribbing as the only thing preventing collapse, yet the recommended immediate treatment requires hiring a structural engineer to design new concrete footings before reconstruction can begin. No structural engineer's report is cited or attached. Proceeding with any work that disturbs adjacent foundations or removes supporting additions before that engineering design is complete could trigger sudden structural failure of the west wall and upper level. The agency must make the structural engineer's report public and confirm it has been incorporated into the work sequence before any contract is awarded.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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