United States Region 3
Environmental Protection Sixth and Walnut Streets
Agency Philadelphia, PA 19106 September 1981
<&EPA Final Environmental Impact
Statement
Gettysburg, PA Area
Wastewater Treatment Facilities
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II!
6th AND WALNUT STREETS
PHILADELPHIA, PENNSYLVANIA 19106
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS, AND CITIZENS:
Enclosed is a copy of the Final Environmental Impact Statement (EIS)
prepared by the U.S. Environmental Protection Agency (EPA) in conjunction
with wastewater treatment facilities plans for Gettysburg and surrounding
Townships in Adams County, Pennsylvania.
This Final EIS is being issued for public review in accordance with the
National Environmental Policy Act of 1969, the Clean Water Act of 1977, and
regulations promulgated by this Agency (40 CFR, Part 6, November 6, 1979).
Comments or inquiries concerning this EIS should be submitted to the
attention of Mr. Thomas Slenkamp at the above address by October 9 , 1981.
EPA recommends as part of this Final EIS that three separate projects be
carried out: (1) Improvement and expansion of the existing Gettysburg
sewage treatment facility to handle current users plus the Route 30 east
area of Straban Townshp; (2) Improvement and expansion of the existing
Cumberland Township sewage treatment facility for the current service area
and adjacent areas in Cumberland Township; and (3) Construction of a
pressurized sewer system for the Lake Heritage community with transmission
to a new sewage treatment facility.
As a means of protecting historic and archaeologic resources which could be
affected by the first two projects, EPA has worked with local communities to
develop a set of mitigative measures which are described in detail in
Chapter V. The cornerstone of these calls for establishment of locally
controlled Historic Districts which cover the areas of the project's
potential impact.
I wish to thank the three prospective grant applicants for the assistance
provided to EPA's staff during this EIS process. I especially want to thank
members of the Public Advisory Group who devoted considerable time and
effort to provide the public a window through which to view these plans.
And finally, I wish to thank the area's citizens and encourage you to work
with your local governments to ensure that the recommended projects and
protection measures are fully implemented.
A public meeting regarding the Final EIS will be held on September 29, 1981 at
7:30 p.m. in the (old) Adams County Courthouse Both the public
and representatives of organizations are encouraged to attend and express
their comments and opinions on EPA's recommendations.
Sincerelv vours.
yvwvut w- VdexA-c* <
George D. Pence, Jr., Chief
Environmental Impact Branch
Enclosure
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FINAL ENVIRONMENTAL IMPACT STATEMENT
WASTEWATER MANAGEMENT FACILITIES
IN THE GETTYSBURG, PENNSYLVANIA AREA
Prepared by
US Environmental Protection Agency
Region III
Philadelphia, Pennsylvania
Thomas A. Slenkamp, Project Monitor
Prepared with the assistance of
WAPORA, Inc.
Chevy Chase, Maryland
Type of Action:
Legislative ( )
Administrative ( X )
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EXECUTIVE SUMMARY
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GETTYSBURG FINAL EIS This Final Environmental Impact Statement (EIS) has been prepared
EXECUTIVE SUMMARY by the Region III Office of the U.S. Environmental Protection
Agency (EPA). It was prepared under the National Environmental
Policy Act (NEPA), which requires all Federal agencies to prepare
EIS's when major Federal actions (e.g. funding of wastewater
treatment facilities) could significantly affect the quality of
the environment.
It's purpose is to address salient comments received on the Draft
EIS which was issued in December 1980, and to recommend a
wastewater management alternative for the Gettysburg area. This
Final EIS is the conclusion of a planning process which has been
ongoing for several years to simultaneously solve water pollution
problems while preserving environmental and cultural resources,
especially those associated with Gettysburg National Park.
Draft EIS The Draft EIS presented five possible alternatives for handling
wastewater treatment needs. They are outlined in the chart below
in terms of which central sewage treatment plants would be
improved, expanded, or eliminated, and which areas (segments)
would be served.
FEASIBLE ALTERNATIVES
Alternative Major Components Segments Served
A Upgrade Gettysburg STP 1,3
Upgrade Cumberland STP 2
Construct New STP for Schaff's
Trailer Park Part of 4
Construct New STP for Lake Hertiage
holding tanks 7-11
Improve on-site systems as needed 4,7-12,14-18,20
B Upgrade Gettysburg STP 1»3,4
Upgrade Cumberland STP 2
Construct New STP for Lake Heritage
holding tanks 7-11
Improve on-site systems as needed 7-12,14-18,20
C Upgrade Gettysburg STP 1,3
Upgrade Cumberland STP 2
Construct Land Application system
for Segment 4 4
Construct New STP for Lake Heritage
holding tanks 7-11
Improve on-site systems 7-12,14-18,20
D Upgrade Gettysburg STP 1,3,4,18
Upgrade Cumberland STP 2,17
Construct New STP for Lake Heritage 7-11
Improve on-site systems 12,14-16,20
E Upgrade Gettysburg STP 1-4,17-18
Construct New Lake Heritage STP 7-11,20
improve on-site systems 12,14-16
EPA indicated no preferences among the alternatives in the Draft
EIS; rather, a variety of information (cost estimates,
environmental effects, available technologies, etc.) was provided
to enable the reader to decide which alternative might be the
most "cost-effective".
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8 | SEGMENT
SEGMENT MAP
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Public Comments EPA received many written and verbal comments on the Draft EIS
during a formal public comment period from December 12, 1980 to
February 10, 1981. In addition, oral testimony on the Draft EIS
was recorded at a Public Hearing conducted by EPA at the Adams
County Courthouse on January 28, 1981. Comments on the Draft EIS
were in the form of questions, new information, suggestions for
improvements to the document, and recommendations for selecting
an alternative.
EPA reviewed all comments and determined those of greatest
concern based on the frequency of comment cr the importance of
the issue to local, State, or Federal government decision making
responsibilities.
Key public comments involved the following isssues:
o Reserve treatment capacities for anticipated future needs
o Treatment technologies available to meet defined needs
o Overall project costs and expected local cost burdens,
including individual user charge estimates
o Methods recommended for concurrently protecting historic and
archaeologic resources from project impacts
o Levels of treatment necessary to protect water quality in area
streams
o Feasibility of on-site systems in areas where sewer service is
not cost-effective
These key comments are responded to in Chapter III. From EPA's
persepective, all comments made were considered beneficial in
assisting the Agency to refine the Draft EIS analysis and to make
final recommendations on fundable alternatives. All written
comments received are reprinted in Appendix B.
Final Alternatives In determining which alternative should be recommended, EPA
Evaluation considered estimated costs, environmental impacts, public and
government agency preferences, and potential for successful
implementation. The objective was to determine the best (most
cost-effective) alternative for the overall planning area, all
factors considered. The roughly equivalent cost estimates and
similarity of impacts among most alternatives meant that large
weight was given to public/community preferences and ease of
implementation.
Costs A review of the cost estimates presented in the Draft EIS
indicates that, with the exception of Alternative A, the
alternatives' present worth costs (those dollars necessary to
construct, operate, and maintain the facilities over the 20 year
planning period) are not appreciably different from one another
(all were within + 10%). Alternative A is significantly lower in
costs than the others, but is not directly comparable due to its
limited service population. Alternatives D and E are more
expensive due to the more extensive sewering involved with these.
EPA also considered estimated costs to individual users inasmuch
as they affect public acceptability and ease of implementation.
Estimated annual user charges vary widely ($118-548) , depending
on the user's location (municipality) and to a lesser extent on
the alternative selected. That is, where a person lives will
have more of an effect on his sewer rates than which particular
alternative is selected. In addition, the estimates themselves
are rough and are subject to change depending on level of Federal
funding available, actual construction costs and the financing
system used by local municipal authorities to bill customers.
Nevertheless, the cost burden to municipalities and individual
users was also taken into account.
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Environmental The environmental impact comparison from the Draft EIS shows that
Considerations while all the alternatives will convey, on balance, more positive
than negative effects, there are relatively minor impact
differences among them. Also, resolution of a key issue of this
EIS, impacts on historic and archaeologic resources, would be the
same in principle irregardless of alternative selected.
To sharpen the distinction among the alternatives in terms of
environmental impacts, EPA performed several additional tasks
after the Draft EIS was issued:
o Supplemental photographic field work from strategic National
Park focal points
o Water quality modeling for impact analysis and effluent
discharge limitations
o Analysis of viewsheds, or panoramas, based on topographic and
vegetative features
o Growth distribution predictions by alternative
After reanalyzing the environmental evaluations based on public
comments received, EPA reached the following conclusions:
Alternatives B and C are environmentally prefereable, by a slim
margin, to the other alternatives. Alternative A, while
seemingly less obtrusive because of limited facilities
construction and sewered service area, is considered less
desirable environmentally than B or C because of its lack of
growth control and heavy reliance on on-site systems in areas of
poor soil suitability. Alternative D is considered inferior to
A,B, and C as it would induce growth into prime agricultural
areas and conforms less to local desires concerning future growth
and land use. Alternative E is least desirable environmentally,
not because it is the only alternative which calls for sewering
Lake Heritage, but because it would convey all wastewater flow
from the upper segments north of Gettysburg into an expanded
Gettysburg STP, causing excessive induced growth, a larger, more
concentrated, water quality impact on Rock Creek, and a strain on
the amount of land necesary for the STP expansion, already of
limited availability.
Community With these factors in mind, EPA considered the preferences of
Preferences local governments and municipal authorities, State and Federal
Agencies, and the public at large.
Of the communities within the planning area, three registered
specific preferences about the selection of an alternative
wastewater treatment system. Cumberland Township endorsed
Alternative D, with some qualifications, as the one being closest
to meeting the interests of Cumberland. Straban Township
expressed a desire for Alternative B, provided that a sufficient
amount of capacity will be reserved for Straban in an expanded
Gettysburg STP. The Lake Heritage community voiced the most and
the strongest opinions about the alternatives available, in their
case, either a pressurized sewer system or continued use of a
combination of holding tanks and other on-site systems. The Lake
Heritage Municipal Authority endorsed Alternative E as the only
acceptable solution to the unique needs of Lake Heritage. The
Lake Heritage Property Owners Association, after some initial
reservations, also decided to support Alternative E. In
addition, a majority of letters received from Lake Heritage
residents indicated support for a sewered vs. non-sewered
approach. The Borough of Gettysburg voiced no specific
preferences, but indicated that they desired the most expedient
solution possible.
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Recommended
Alternative
'me Pennsylvania Department of Environmental Resources raised
several questions about the Draft EIS, but generally supported
local preferences on the alternatives. The National Park Service
was likewise supportive of local governments desires as long as
they could be assured that any improved facilities would not be
detrimental to historic and archaeologic resources in the area.
Several other government agencies commented on the Draft EIS,
with about half encouraging a specific alternative. (See
Appendix B).
General public comments were divided about equally between those
on Lake Heritage and those on other areas, with about one-third
expressing specific alternative preferences. Many individual
commenters wanted to see strong historic protection measures
applied, regardless of the alternative selected.
With a final consideration given to all of the above factors, EPA
recommends the following alternative for implementation:
Components of Recommended Alternative
Municipality Draft EIS Alternative Segments Sewered
Gettysburg/Straban
Cumberland
Lake Heritage
B
D
E
1. 3, 4
2, 17
7-11, 20
Protection of
Historic Resources
Under the recommended alternative (See Figure), Cumberland
Township will upgrade its north plant and expand it to
accommodate future needs in Segments 2 and 17. The existing
Gettysburg STP will be upgraded and expanded to serve existing
users (the Borough of Gettysburg and the Twin Oaks subdivision)
plus the Route 30 East area of Straban Township (Segment 4) and a
small amount of holding tank waste from Segment 18. The Lake
Heritage community (Segments 7-10) , Hazelbrook Hills (Segment
11) , and Little Drummer Boy Campground (Segment 20), will be
served by a pressure sewer system, with the wastewater flow being
treated at an improved STP located south of the lake below Route
97. The improved Lake Heritage STP will also treat holding tank
waste from Segments 12 and 14-16.
The capital cost estimates for the three combined projects is
$18,098,200.
Along with the recommended wastewater treatment alternative, EPA
recommends that a set of preventive mesures be carried out for
protecting valuable historic and archaeologic resources. These
measures are contained in a Memorandum of Agreement developed
during the EIS process through a series of meetings among local,
State, and Federal representatives. The MOA has been developed
in accordance with the requirements of the National Historic
Preservation Act and supporting regulations.
A chief mitigative measures calls for Cumberland and Straban
Townships to establish and administer Historic Districts under
the Pennsylvania Historic District Act. The districts will
provide for local review of future development . to ensure its
consistency with the historic, archaeologic, and architectural
character of the area.
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GETTYSBURG ^
I r-i
V—' I
PLANNING AREA BOUNDARY
SEGMENT BOUNDARIES
|8 SEGMENT NUMBER
.^r.. WASTEWATER CONVEYANCE ROUTE
¦ SEWAGE TREATMENT PLANT (STP)
* SEGMENT SERVED BY
GETTYSBURG STP
,3.4,18
CUMBERLAND STP
7,8,9,10,11,20 NEW LAKE HERITAGE STP
MILE
RECOMMENDED ALTERNATIVE
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other protective raesures outlined in the MGA call for
archaeologic surveys in areas of wastewater facility
construction, a determination of eligibility for National
recognition of any newly discovered resources, design of
wastewater faciities to minimize visual effects, and a program to
explain the advantages of scenic easements to area property
owners.
Many of these measures will take place during design of the
wastewater treatment projects, but all must be completed prior to
construction. Local governments and citizens are encouraged to
work together with the State Historic Preservation Office
(Pennsylvania Historic and Museum Commission) and the National
Park Service to implement these measures in an effective and
expeditious manner.
The responsibility for final decisionmaking on Federal funding of
the recommended projects lies with the EPA Regional
Administrator. The prospective grantees (Gettysburg, Cumberland,
and Lake Heritage Municipal Authorities) must work with the State
Department of Environmental Resources to fulfill requirements for
Step 2 (design) and Step 3 (construction) funding. DER then will
submit the projects to EPA for approval.
Following the close of a 30-day comment period on the Final EIS,
EPA will be in a position to make grant awards. Later this year,
EPA will prepare a Record of Decision which will set forth the
conclusions of the EIS process, the decisions made by DER and EPA
on the funding level of alternatives, and the subsequent actions
to be taken by the grantees.
A final public meeting to discuss the recommendations presented
in the Final EIS will be held in Gettysburg as specified in the
cover letter of this document.
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TABLE OF CONTENTS
Page
Executive Summary .1
Table of Contents
List of Tables *
List of Figures
List of Acronyms and Abbreviations xil
I. Introduction 1
II. Summary of the Draft EIS 3
III. Public and Agency Comments on Draft EIS 13
IV. Final Evaluation of Alternatives 39
V. Protection of Historic and Archaeologic Resources 47
Final EIS Mailing List 53
Bibliography 57
Appendices
A. Draft EIS Included by Reference A-l
B. Comment Letters B-l
C. Evaluation of Treatment Requirements for Rock Creek C-l
D. Revised DEIS Appendix G-7 D-l
E. DEIS Appendix G-8 E-l
F. Engineering Cost Information F-l
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11
12
16
31
41
42
43
43
43
44
44
44
TABLES
Major Components and Segments Served by EIS Alternatives
Summary of Environmental Effects of Alternative Wastewater
Management Systems in the Study Area
Comparison of Projected Baseline and Induced Growth Impacts by
Alternative, Segment, and Municipality for Population and Housing
Units
Land Marks, Compatible Features, and Intrusions Visible from Oak
Ridge Observatory, Peace Memorial Drive, and Barlow's Knoll and
Culp's Hill
Components of the Recommended Alternative
Wastewater Management in the Recommended Alternative
Wastewater Flows for the Recommended Alternative
Capital Cost of the Recommended Alternative
Annual O & M Costs of the Recommended Alternative
Salvage Value of the Proposed Projects
Total Present Worth by Project
Local Share and User Charges for the Recommended Alternative
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4
5
6
7
8
10
27
30
32
34
35
36
40
FIGURES
Segment Map
Alternative A
Alternative B
Alternative C
Alternative D
Alternative E
Future Land Use 2005
Scenic Views from Photographic Stations in Gettysburg National
Historic District
Potentially Impacted Visual Resources in the Gettysburg Study
Area
Areas Designated as Critical by ACHP
Hypothetical Secondary Visual Impact in Areas to be Sewered
Hypothetical Secondary Visual Impacts in Areas to be Sewered
Recommended Alternative
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LIST OF ABBREVIATIONS
ACHP Advisory Council of Historic Preservation
ACPC Adams County Planning Commission
AQCR Air Quality Control Region
BODg Five-day Biochemical Oxygen Demand
BOD Biochemical Oxygen Demand
cfs Cubic foot per second
BAQNC Bureau of Air Quality and Noise Control
EIS Environmental Impact Statement
EPA Environmental Protection Agency
GASD Gettysburg Area School District
GFCC Gannett, Fleming, Corddry, and Carpenter, Inc.
GMA Gettysburg Municipal Authority
gpcd Gallons per capita per day
gpd Gallons per day
HGAC Historic Gettysburg-Adams County
HUD Housing and Urban Development
I/I Infiltration/Inflow
LASD Littlestown Area School District
LHMA Lake Heritage Municipal Authority
mgd Million gallons per day
mg/1 Miligrams per liter
msl Mean sea level
NAAQS National Ambient Air Quality Standards
NBOD Nitrogenous Biochemical Oxygen Demand
NEPA National Environmental Policy Act
NHPA National Historic Preservation Act
NPS National Park Service
O & M Operation and Maintenance
PA-DER Pennsylvania Department of Environmental Resources
PAG Public Advisory Group
PIHP Pennsylvania Inventory of Historic Places
PSD Prevention of Significant Deterioration
SEO Sewage Enforcement Officer
SHPO State Historic Preservation Officer
ST/SAS Septic Tank-Soil Absorption Systems
STP Sewage Treatment Plant
TDS Total Dissolved Solids
TSP Total Suspended Particulates
TSS Total Suspended Solids
USDA US Department of Agriculture
USDOC US Department of Commerce
USGS US Geological Survey
7Q10 Seven-day ten-year low flow
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CHAPTER I
Introduction
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CHAPTER I
INTRODUCTION
This Final Environmental Impact Statement (EIS) has been prepared
in conjunction with wastewater facilities plans and applications
for Federal construction grants submitted to the U.S. Environ-
mental Protection Agency (U.S. EPA) in the area of Gettysburg,
Pennsylvania. The Gettysburg Municipal Authority (GMA) initially
requested Federal financial assistance from EPA in 1976 in order
to carry out their proposed plan for a regional wastewater treat-
ment system for Gettysburg and surrounding townships in Adams
County, Pennsylvania. Under the National Environmental Policy
Act (NEPA), EPA is responsible for making the public aware of any
significant environmental consequences that may occur as a result
of any proposed project involving a Federal government action.
Because questions have been raised about the impacts that this
project may have on the local communities and the Gettysburg
National Park, EPA decided to prepare an EIS.
EPA's Notice of Intent to prepare an EIS was issued on February
16, 1979. A Draft EIS was distributed to the public and govern-
ment agencies on December 12, 1980. The Draft EIS is summarized
in Section II of this Final EIS. Aside from that summation, the
content of the Draft EIS is not repeated in this document. When
necessary, contents of the Draft EIS are herein referred to by
page (i.e., DEIS, 21). The Draft EIS is available for review at
local and county libraries and municipal offices. Copies of the
Draft EIS have been distributed to Federal agencies, state
agencies, Federal and state elected officials, local government
agencies, environmental interest groups, citizens, and numerous
other individuals and organizations.
A public hearing on the Draft EIS was conducted by EPA at the
Adams County Court House in Gettysburg Borough on January 28,
1981, at which time local officials and other interested parties
presented their comments and recommendations concerning this
project. Written comments also were received by EPA during a
public comment period that commenced with the distribution of the
Draft EIS (December 12, 1980) and ended on February 10, 1981.
Public and agency comments on the Draft EIS are presented and
addressed in Chapter III of this document.
The primary purpose of the Final EIS is to evaluate and address
questions, comments, and recommendations received during the
commenting period. By doing so, the critical issues concerning
this project are clarified, enabling EPA to present its recom-
mendations on alternatives eligible for funding by the Agency.
The final evaluation of alternatives is presented in Chapter IV of
this document.
The Final EIS has two other purposes. First, it presents a Final
Memorandum of Agreement (MOA) among all concerned parties on the
protection of historic and archaeological resources in the Study
Area. Mitigative measures and timing of the adoption of the MOA
are established in the Agreement. Mitigative measures proposed
include the stipulation for an archaeologic survey of all pro-
posed wastewater collection and treatment facility sites, design
of all facilities to minimize visual impacts, establishment of
municipal historic district ordinances, and the formulation of a
scenic easement program.
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Second, the Final EIS provides guidance for the successful imple-
mentation of recommended alternatives by the grant applicants,
the state, and EPA. Questions regarding design capacity of
facilities, funding eligibility, and management responsibilities
are addressed in this document.
Alternative
Selection Process
Through the EIS process, several alternatives for improved waste-
water management have been developed and evaluated. Details
about the most feasible of these were presented for public con-
sideration in the Draft EIS. Both the costs and environmental
impact information have been carefully reviewed and commented on
by area residents and other interested parties to determine the
preferable alternatives.
EPA has evaluated all comments received and made necessary
changes to the alternatives analysis based on these comments. A
response to substantive comments is provided in this Final EIS.
Also in this Final EIS, EPA has identified a recommended alter-
native for implementation, with consideration given to public
comments, local government positions, and the cost and impact
evaluations.
Following publication of this Final EIS, each local jurisdiction
or municipal authority must decide which course of action they
wish to pursue. If local decisions are consistent with the
results of the EIS, applications for Federal funding to design
and construct wastewater treatment facilities can then be pro-
cessed.
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CHAPTER II
Summary of Draft EIS
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CHAPTER II.
SUMMARY OF DRAFT EIS
This section addresses the goals, alternatives, and conclusions
of the Draft EIS.
Goal
The primary goal of the Draft EIS was to develop solutions to the
existing and probable wastewater disposal problems for the
Gettysburg area that are cost-effective and environmentally
sound. The Draft EIS established an information base upon which
rational decisions could be made by local jurisdictions and
authorities when they apply for construction grant funds, as well
as by PA-DER and EPA in deciding whether to award the funds. In
order to achieve this goal, the following objectives were set for
examination in the Draft EIS:
• To eliminate the water quality problems in Rock Creek and
other surface waters
• To minimize costs for wastewater management for the Gettysburg
area
• To minimize impacts on historic and archaeological resources
and to develop mitigative measures to control secondary
impacts resulting from induced growth.
Draft EIS Alternatives
The following summary describes the alternatives that were pre-
sented in the Draft EIS. The alternatives are described on a
segment basis. Figure II-l illustrates the division of the Study
Area into segments. Alternative A, Figure II-2, the "limited
action" alternative consists of upgrading the Gettysburg Sewage
Treatment Plant (STP) to serve segments 1 and 4 and Cumberland
Township STP to handle existing flows from segment 2; construct-
ing a new STP for the Schaff's Trailer Park; and constructing a
new STP for Lake Heritage residents, who would continue to use a
combination of septic tanks and holding tanks.
Alternative B, Figure I1-3, calls for upgrading and expanding the
Gettysburg STP to accommodate currently sewered areas plus Route
30 east (Segment 4) in Straban Township. The Cumberland STP
would be upgraded for currently served areas. A new Lake
Heritage STP would be constructed to handle that area's septic
tank and holding tank wastes. Areas north of Gettysburg in
Cumberland and Straban Townships would be accommodated by on-site
systems.
Under Alternative C, Figure I1-4, Gettysburg and Cumberland STP's
would be upgraded to handle the existing service area only. A
new land treatment system would be built to serve Route 30 east
in Straban Township. A new STP would be constructed to handle
septic/ holding tank waste from Lake Heritage homes. Areas north
of Gettysburg in Cumberland and Straban Townships would be accom-
modated by on-site systems.
Under Alternative D, Figure I1-5, the Gettysburg STP would be
upgraded and expanded to accommodate currently served areas plus
portions of Straban Township along Route 30 east and Business
Route 15 north. Cumberland STP would also be upgraded and en-
larged to serve an expanded area along Route 34 north of Gettys-
3
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%
I
Tl
)
/
r 1
8 | SEGMENT
FIGURE II-l
SEGMENT MAP
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MILE
1
I
FIGURE 11-2
ALTERNATIVE A
\
\
PLANNING AREA BOUNDARY
SEGMENT BOUNDARIES
|g SEGMENT NUMBER
WASTEWATER CONVEYANCE ROUTE
¦ SEWAGE TREATMENT PLANT (STP)
I SEGMENT
I
I
SERVED BY
1,3
GETTYSBURG STP
2
CUMBERLAND STP
7,8,9,10,1)
NEW LAKE HERITAGE STP
4,17,18
ON-SITE SYSTEMS
TRAILER
NEW SCHAFF STP
PARK
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FIGURE 11-3
ALTERNATIVE B
/
/ PLANNING AREA BOUNDARY
SEGMENT BOUNDARIES
18 SEGMENT NUMBER
WASTEWATER CONVEYANCE ROUTE
¦ SEWAGE TREATMENT PLANT (STP)
SEGMENT SERVED BY
1,3,4
2
/
I
| 7,8,9,10,11
/ 17,18
GETTYSBURG STP
CUMBERLAND STP
NEW LAKE HERITAGE STP
ON-SITE SYSTEMS
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FIGURE 11-4
ALTERNATIVE C
/
PLANNING AREA BOUNDARY
SEGMENT BOUNDARIES
18 SEGMENT NUMBER
WASTEWATER CONVEYANCE ROUTE
¦ SEWAGE TREATMENT PLANT (STP)
SEGMENT
1,3
2
/
I
j 7,8,9,10,11
J 4
17,18
SERVED BY
GETTYSBURG STP
CUMBERLAND STP
NEW LAKE HERITAGE STP
OVERLAND FLOW
ON-SITE SYSTEMS
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FIGURE 11-5
ALTERNATIVE D
V SEGMENT
,3.4,18
7,8,9,10,11
/ PLANNING AREA BOUNDARY
SEGMENT BOUNDARIES oo
18 SEGMENT NUMBER
WASTEWATER CONVEYANCE ROUTE
¦ SEWAGE TREATMENT PLANT (STP)
SERVED BY
GETTYSBURG STP
CUMBERLAND STP
NEW LAKE HERITAGE STP
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Gettysburg
n i I /
FIGURE 11-6
ALTERNATIVE E
MILE
r
1
\
Ov
PLANNING AREA BOUNDARY
SEGMENT BOUNDARIES
|8 SEGMENT NUMBER
WASTEWATER CONVEYANCE ROUTE
¦ SEWAGE TREATMENT PLANT (STP)
\SEGMENT
I
I
17,
3,4
18
SERVED BY
GETTYSBURG STP
I
* 7,8,9,10,11 NEW LAKE HERITAGE STP
)
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burg. A new STP would be constructed to treat septic and holding
tank wastes from Lake Heritage.
Alternative E, Figure II-6, is the most centralized option and
consists of upgrading the Gettysburg Sewage Treatment Plant to
serve the Borough as well as the areas to the north in Cumberland
and Straban Townships. New collection and treatment facilities
would be constructed for all of the Lake Heritage area. For the
segments to be served by decentralized treatment, 12, 14, 15, and
16, improvement of on-site systems is proposed.
Draft EIS Findings
On December 12, 1980, a Draft EIS on this project was issued by
EPA. The Draft EIS presented these five alternative wastewater
management systems which incorporated alternative approaches for
resolving wastewater treatment problems. Table Il-l summarizes
centralized and decentralized approaches, described in the Draft
EIS, which are suggested to satisfy Gettysburg area's wastewater
management needs.
A primary purpose of the Draft EIS was to identify wastewater
management solutions which were implementable, cost-effective,
environmentally sound, and grant eligible. The Draft EIS made no
specific recommendations concerning preferred alternatives.
Instead, probable adverse and beneficial effects of each approach
were identified as well as the costs expected to be incurred.
The alternative wastewater management system identified in the
Draft EIS were demonstrated to have varying effects upon the
existing and future environmental setting in the planning area.
The environmental categories which specifically were addressed in
the Draft EIS include:
• land use
• population growth
• earth resources
• water resources
• air quality/noise levels
• socioeconomic conditions
• cultural resources.
Table 11-2 summarizes the adverse and beneficial environmental
impact of these alternative wastewater management systems. These
impacts are characterized by directness of impact (primary or
secondary) and anticipated severity. Primary impacts are direct
effects on the environment of the construction and operation of
the wastewater facilities. Secondary impacts are indirect o^
induced changes in the environment resulting from the operation
and availability of the wastewater facility and wastewater treat-
ment service. Secondary impacts would include the induced
changes in the pattern of land use, population density and re-
lated effects on air and water quality or other natural
resources.
10
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Table II-l.
Major Components and Segments Served by EIS
Alternatives
FEASIBLE ALTERNATIVES
Alternative
Major Components Segments Served
Sewered?
A
Upgrade Gettysburg STP
1,3
Yes
Upgrade Cumberland STP
2
Yes
Construct New STP for Schaff1s
Trailer Park
Part of 4
Yes
Construct New STP for Lake
Heritage holding tanks
7-11
No
Improve on-site systems as
needed
4,7-12,14-17,18,20
No
B
Upgrade Gettysburg STP
1,3,4
Yes
Upgrade Cumberland STP
2
Yes
Construct New STP for Lake
Heritage holding tanks
7-11
No
Improve on-site systems as
needed
7-12,14-17,1820
No
C
Upgrade Gettysburg STP
1,3
Yes
Upgrade Cumberland STP
2
Yes
Construct Land Application
system for Segment 4
4
Yes
Construct New STP for Lake
Heritage holding tanks
7-11
No
Improve on-site systems
7-12,14-17,18,20
No
D
Upgrade Gettysburg STP
1,3,4,18
Yes
Upgrade Cumberland STP
2,17
Yes
Construct New STP for Lake
Heritage
7-11
No
Improve on-site systems
12,14-16,20
No
E
Upgrade Gettysburg STP
1-4,17-18
Yes
Construct New Lake Heritage STP
7-11,20
Yes
Improve on-site systems
12,14-16
No
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Table I1-2. Summary of Environmental Effects of Alternative Wastewater Management Systems in the Study Area
Environmental effect
(by environmental category)
Type of Impact
Primary Secondary
Probability of Occurrence
of Impact Alternatives
High Moderate A B C D E RA
Land Use
1. Conversion of undeveloped
land to developed uses
2. Compatibility of future land
uses with local plans and
policies
3. Conformance with conservation
and density objectives of muni-
cipal growth management plans
Population
1. Inducement for population
increase
2. Inducement for shifting of
population increase in the
planning area
Earth Resources
1. Prime agricultural land
2. Erosion and sedimentation
3. Groundwater supply/recharge
Water Resources
1. Surface waters quality
2. Groundwater quality
3. Frequency/intensity of
downstream flooding
Socioeconomic Conditions
1. Customer cost for waste-
water service
2- Utilization of school
facilities due to popula-
tion increase
o o o o o
o o o
Historical and Archaeological Resources
1. Aesthetic value of landscape, •
open space, and vistas
2. Noise, air, and aesthetic •
effects of STP on potential
district
3.
Prehistoric archaeologic
sites
Key: + Beneficial Impact
o Negligible Impact
- Adverse Ijnpact
— Significant Adverse Impact
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CHAPTER III
Public and Agency Comments on Draft EIS
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CHAPTER III
PUBLIC AND AGENCY
COMMENTS ON DRAFT EIS
In accordance with the National Environmental Policy Act and EPA
procedures for the preparation of environmental impact state-
ments, Federal, State, and local agencies as well as the public
were requested to comment on the Draft EIS from December 12, 1980
to February 10, 1981. In addition, oral testimony on the Draft
EIS was received at the Public Hearing held on January 28, 1981.
Comments on the Draft EIS included questions, new information,
recommendations on improvements to the document, and recommenda-
tions for selecting alternatives. Preferences for alternative
systems are summarized in Chapter IV. In total, written comments
were received by EPA from Federal agencies, State agencies,
county agencies, regional agencies, municipal authorities, and
numerous citizens and interest groups. In addition, testimony at
the public hearing on the Draft EIS was made by representatives
of one State agency, three municipal authorities, and several
citizens.
From the perspective of EPA, all comments concerning the Draft
EIS were beneficial in assisting the Agency to refine its
analysis of this project and in making final recommendations
concerning fundable alternatives. From all the comments re-
ceived, however, the following questions are considered by EPA to
be among the most critical comments, based on the direct
importance of the issue to the Agency's decision-making responsi-
bilities :
Key Comments
• What are the treatment capacities available to local townships,
and is this capacity sufficient for the design period?
• What are the design options considered for the Lake Heritage
area?
• What are the overall project costs, the local share of that
cost, and resultant user charges?
• Given the wastewater treatment needs defined in the Draft EIS,
will the alternatives address the public health and water
quality problems identified?
• Is advanced secondary treatment (AST) necessary in light of
the DER proposed effluent limits and the results of water
quality modeling accomplished as part of this EIS?
• What is the feasibility of upgrading on-site systems in pro-
blem areas where no sewer service is proposed?
• What are the anticipated impacts on historic and archaeologic
resources from residential or commercial growth that will be
induced by the Alternatives?
13
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• What are the realistic mitigative measures necessary to pro-
tect historic and archaeologic resources from the recommended
alternative and are they sufficient to ensure negotiation of
Memorandum of Agreement (MOA)?
• What are the impact areas that must be covered in MOA?
These questions and each of the issues identified are addressed
in the following sections:
• Response to comments on existing conditions.
• Response to comments on wastewater management alternatives.
• Response to comments on water quality justifications.
• Response to comments on historic and archaeologic impacts and
mitigative measures.
Because many of the comments and issues were addressed by more
than one organization or person, the comments that are discussed
have been reformulated by EPA to indicate the central concerns of
the commenting parties. Sources of the comments can be ascer-
tained from Appendix B, where the full text of comment letters is
presented.
EXISTING CONDITIONS:
COMMENTS AND RESPONSES
Each of the following comments and responses concern existing
conditions and issues in the planning area. The issues must be
resolved in order to finalize the alternatives and assess envi-
ronmental impacts.
General Population
Projections
Issue 1: Several commenters have questioned the reasonableness
of the population projections used in the EIS process. Also,
during recent meetings with municipalities in the Study Area,
commenters indicated that they were confused by the different
population projection tables in the DEIS and Appendices and by
the concept of baseline projections themselves, as well as the
manner in which these baseline projections provided the basis for
design flow calculations in the alternatives development.
Response to Issue 1: Population projections for all munici-
palities and Study Area portions of municipalities are summarized
(Table II1-5, p. 38) and explained (pp. 37-40) in the DEIS. DEIS
Appendix F describes the methodologies used to calculate the
projections for the five municipalities as well as the methodo-
logies used to break out the projections for the Study Area
portions of these five municipalities. DEIS Appendix F also
reviews other population projections evaluated during this EIS
process.
The population projections used by EPA for waste planning pur-
poses (Table 111-5, Tables 2 and 3 in Appendix F-l, Table 2 in
Appendix F-3, the last columns of Tables A and B in Appendix
F-10, and Table IV-7 in the DEIS, incorrectly labelled Table
II1-7) are described as baseline projections. These baseline
projections are intended to accommodate a reasonable amount of
-------
growth, taking into account overall State, regional, and county
growth; major developments in the five municipalities; and
regulations/guidance from the U.S. Council on Environmental
Quality and other Federal agencies. Past development trends and
other land use factors were used to distribute baseline growth in
such a way as to understand where growth would occur. Baseline
population with associated land development is depicted in Figure
III-7 of the Draft EIS. These baseline population and associated
housing unit projections are separated by five-year periods and
increments in Tables 2 and 3 in Appendix F-l and are translated
into both housing units and acres absorbed by new development in
Tables A and B in Appendix F-10 which, in turn, is keyed to
Figure II1-7. Baseline projections and future development
directly have been used in the development of alternatives (Table
IV-7/III-7). Existing and future user needs have been tallied by
segment and then translated into flows by alternative (Table
IV-9).
The concept of induced growth stimulated by any of the alterna-
tives is discussed in the impact discussion of the DEIS (pp.
119-125) and is presented in Table V-2. (It should be noted that
the concept of induced growth applied in this EIS is not value
influenced and does not suggest positive or negative effects;
induced growth estimates are variations from baseline patterns.)
DEIS Appendix F-10 describes the induced growth and overall
impact methodology in greater detail with Tables A and B indicat-
ing housing unit and associated acreage counts by alternative by
municipality by segment (baseline growth also is provided for
comparison). For the purpose of clarification, a new descriptive
table (Table III-l) has been developed to summarize the vital in-
duced growth and overall impact findings and contrast these
findings with baseline projections. As was stated in the DEIS
(p. 120), the induced growth effects of any of the alternatives
are not sizable, largely as a result of the careful engineering
of sewage treatment and conveyance facilities in all alterna-
tives. Nevertheless, some of the alternatives (B, D, and E) can
be expected to result in population shifts or redistributions
between segments, as well as potential acceleration in growth
rates such that year 2005 baseline projected growth could be
reached earlier. The basic theme which emerges from Table III-l
is that, by sewering the Route 30 east area (Segment 4) in
Straban Township, future growth can be expected to be attracted
away from areas north of Gettysburg Borough (Segment 17 in
Cumberland and Segment 18 in Straban). It is important to note
that this redistribution to Segment 4 appears to be positive when
many of the impact areas are evaluated.
Specific Population
Projections
Issue 2: Straban Township specifically has addressed population
projection issues in their letters of 16 January 1981 and 9
February 1981, which questioned the overall projection for the
municipality as well as the distribution of growth (Segment 4
versus Segment 18). Basically, Straban continues to want to
provide sewage capacity for more growth in Segment 4 (Route 30
east) than has been projected by EPA in the baseline projections
(59 dwelling units for 166 people).
Response to Issue 2: The baseline projections prepared for
Straban and the other four municipalities emerged as the result
of EPA's evaluation of all existing population projections,
recent development trends (subdivision approvals, building per-
15
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Table III-l, A Comparison of Projected Baseline and Induced Growth Impacts by
Alternative by Segment by Municipality for Population and Housing
Units"
Alternative A (Baseline)
Cumberland
No
change
from
baseline
future
land
use
Gettysburg
No
change
from
baseline
future
land
use
Mt. Joy
No
change
from
baseline
future
land
use
Mt. Pleasant
No
change
from
baseline
future
land
use
Straban
No change
from
baseline
future
land
use
Alternative B
Cumberland
Gettysburg
Mt. Joy
Mt. Pleasant
Straban
Alternative C
Cumberland
Gettysburg
Mt. Joy
Mt. Pleasant
Straban
Alternative D
Cumberland
Gettysburg
Mt. Joy
Mt. Pleasant
Straban
Alternative E
Cumberland
Gettysburg
Mt. Joy
Mt. Pleasant
Straban
Loss of 420 people and 150 dwelling units in Segment 17
No change from baseline future land use
No change from baseline future land use
No change from baseline future land use
Gain of 420 people and 150 dwelling units in Segment 4;
also internal redistribution of 340 people and 121
dwelling units from Segment 18 to Segment 4, increasing
Segment 4 total by 761 people and 271 dwelling units
when compared to baseline future land use
No change from baseline future land use
No change from baseline future land use
No change from baseline future land use
No change from baseline future land use
Internal redistribution of 295 people and 105 dwelling
units from Segment 18 to Segment 4
No change from baseline future land use
No change from baseline future land use
No change from baseline future land use
No change from baseline future land use
Internal redistribution of 295 people and 105 dwelling
units from Segment 18 to Segment 4
Loss of 395 people and 141 dwelling units in Segment 17
No change from baseline future land use
Loss of 128 people and 42 dwelling units in Segments 10/11
Loss of 75 people and 25 dwelling units in Segment 9
Gain of 452 people and 161 dwelling units total; Segment 18
loses 295 people and 105 dwelling units, Segment 4 gains
691 people and 246 dwelling units, Segments 7 and 8 gain
56 persons and 20 dwelling units
Recommended Alternative
Cumberland No change from baseline future land use
Gettysburg No change from baseline future land use
Mt. Joy No change from baseline future land use
Mt. Pleasant No change from baseline future land use
Straban Gain of 420 people and 150 dwellings units in Segment 4;
also internal redistribution of 340 people and 121 dwelling
units from Segment 18 to Segment 4, increasing Segment 4
total by 761 people and 271 dwelling units when compared to
baseline future land use
* Based on baseline projections for population in Table III-5 (DEIS, p. 38) and
baseline projections for population and housing units in Tables 2 and 3 (DEIS,
Appendix F-l); reflected in baseline projections in Table IV-7/III-7 (DEIS, p,
and design flows given in Table IV-8 (DEIS, pp. 97 and 198). Induced growth
calculations are based on Table V-2 (DEIS, pp. 121 and 122) and Table A and B
in Appendix F-10.
16
95)
-------
mits issued, etc.) obtained from the Adams County Planning
Commission files and other sources such as air photo interpreta-
tion. EPA sought to use existing projections prepared by appro-
priate agencies. In this case, recent projections for Straban
were not available. As a consequence, EPA has estimated current
population and then applied a reasonable rate of growth to the
existing population base. This rate of growth basically is the
same as that developed by the Pennsylvania Department of Com-
munity Affairs for neighboring Cumberland Township during the
preparation of the Cumberland Comprehensive Plan. Because the
two municipalities are so similar in terms of growth determinants
(e.g., demographic factors affecting fertility, net migration
factors, etc.) and because the Cumberland planning process con-
stitutes the most recent throughgoing planning process undertaken
in the area, use of this growth rate was deemed to be reasonable.
One major difficulty in the projection process has been the
necessary development of the Straban population projections prior
to the release of the 1980 U.S. Census counts. EPA and its
consultant utilized then published U.S. Census counts in the
projection process (Table III-5 in the DEIS, p. 38). New resi-
dential development activity was used to extend 1976 estimates to
an existing 1980 population. The 1980 U.S. Census preliminary
count for Straban was 4,030 and was recently revised even higher
to 4,248. Assuming that the U.S. Census count is reasonably
accurate, the 4,248 figure suggests that either there are con-
siderably more housing units in Straban than EPA has been able to
determine from county files (building permits) or that there are
more people living in each housing unit than has been projected
by EPA. The latter explanation based on average household size
appears to be more likely. In many municipalities, the 1980
counts are much higher than previously estimated and are not
compatible with building permit data. (Verbally, Mr. John
Callenbach, Adams County Planning Commission, to Mr. Wesley
Horner, WAPORA, Inc., 21 April 1981.) Publication of detailed
population and housing data for the 1980 count may help to
explain these inconsistencies.
If DEIS population projections were to be adjusted upward using
the 1980 U.S. Census count for Straban, but retaining all prior
assumptions, an increase of approximately 400 additional persons
could result in the Study Area portion of Straban. Most likely
this additional projected population component would be distri-
buted throughout the Study Area portion, though definitely
clustered in the sewered segments. However, if all of this
additional growth were to occur in Segment 4, this total expanded
growth could be accommodated by the Recommended Alternative
(secondary or induced growth impacts have been estimated which
themselves exceed these upwardly adjusted projections for Segment
4; as much as 80,400 gpd [Table IV-8 in the DEIS, pp. 97 and 98]
is available for future growth in Segment 4 if Segment 18 is not
connected, allowing for approximately 350 new units with between
1,000 to 1,100 residents rather than the baseline projection of
59 new units with 166 people). At the same time soils analysis
for Segment 18 suggests that 50% of the baseline projected growth
(320 units or 1,000 persons) could be developed in Segment 18
without public sewers, thereby increasing the net projection for
the Study Area portion of Straban considerably together with the
very substantial increase in Segment 4.
In sum, the Recommended Alternative addresses Straban's concerns
regarding future growth thoroughly. Through the careful sizing,
timing, and overall engineering of system elements, the Recom-
17
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mended Alternative should promote a reasonable amount of new
development in those areas deemed most locally desirable and
least environmentally destructive.
WASTEWATER MANAGEMENT
ALTERNATIVES:
COMMENTS AND RESPONSES
Straban Township
Reserve Capacity
Lake Heritage
Options
Issue 1: The Board of Supervisors for Straban Township voiced
their disagreement with the population projections for Segments 4
and 18. They claim that the majority of growth will be in
Segment 4, not in Segment 18 as projected in the Draft EIS.
Straban has provided documentation supporting their claim of
future development occuring in Segment 4. Straban's projection
for Segment 4 includes 198 existing EDU's, 152 proposed EDU's for
a motel complex under construction, and 150 EDU's for future
development resulting in a total of 500 EDU's. Considering the
above, what is the number of EDU's and the resulting reserve
capacity allocated to Straban in the Recommended Alternative?
Response to Issue 1: When sewers are provided along Rt. 30, the
projected development is expected to shift from Segment 18 to
Segment 4. This shift results in a projection of 330 EDU's in
Segment 4 by 2005. This figure is comparable to the 349 EDU's
projected by the Straban Board of Supervisors (198 existing + 150
future). In addition, Schaff's Trailer Park is expected to have
331 residents and motel rooms are expected to add 108 resident-
equivalents to the total population. These additions represent
approximately 157 EDU's [(331 + 108) -r 2.8]. The total number of
EDU's projected is therefore 487 (157 + 330) which is similar to
the number projected by Straban (500 EDU's). Wastewater flow
projections from Segment 4 can therefore be calculated as
follows:
487 EDU's x 2.8 people/EDU x 75 GPCD - 102,225 gpd
To this flow projection, I/I must be added along with the contri-
bution from the holding tanks in Segment 18. Holding tanks are
expected to serve 100 residents in Segment 18 by the year 2005.
The total capacity reserved for Straban at the Gettysburg STP can
therefore be calculated as follows:
Flow from Segment 4
I/I - Schaff's
I/I - Rt. 30
Segment 18 100 holding tanks x 2,000 gal
14 days
102,225 gpd
2,945 gpd
5,265 gpd
14,286 gpd
Total Straban capacity = 124,721 gpd
Issue 2: Problems with on-site systems such as failing septic
tanks and holding tanks have been identified in the Lake Heritage
area. What options were considered for handling the wastewater
management needs of this area?
Response to Issue 2: The basic options considered for the Lake
Heritage Area were the on-site option and the central collection
and treatment option. Within each of these basic categories many
options were considered. For example, on-site options included
septic tank-sand mound systems and holding tanks. Sewering
options included consideration of conventional gravity, pressure
18
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sewers and vacuum sewers. Treatment options considered include
land application (such as overland flow and marsh-pond systems),
and activated sludge systems, such as the oxidation ditch.
Conventional gravity sewering was eliminated from consideration
because of the expense of installation in areas of rolling
terrain and shallow bedrock. On-site options were more cost-
effective than sewering, but were not recommended as a result of
the existing problems with on-site systems, the expected popula-
tion increase, and the local preference for central collection.
Project Costs
User Charges
Issue 3: Project costs were a contributing factor in recom-
mending the Alternatives for implementation in the Study Area.
What are these costs and how accurate are they?
Response to Issue 3: The Draft EIS presents the results of the
cost-effectiveness analysis. Component costs by municipality are
presented in the Draft EIS and Appendix A of that document.
Costs of the Recommended Action are presented in Chapter IV of
the Final EIS and are summarized below.
Project
Cumberland
Gettysburg/
Straban
Lake Heritage
Total
Present
Worth
($ x 103,
4th Quarter
1979)
3,794.1
11,218.4
7,251.6
Local
Share
(By Segments)
($ x 103,
4 Quarter, 1979)
119.8 (2,17)
1074.7 (1,3)
449.8 (4,18)
818.1 (7-11,20)
32.5 (12,14-16)
1985
Use
Charges
(By Segments)
<$/yr)
332 (2,17)
109 (1,3)
*313 (4,18)
568 (7-11,20)
126 (12,14-16)
Assumes no difference in user charge between Segment 4
(sewered) and Segment 18 (not sewered).
Note that the total present worth figures include costs
associated with the entire project whether or not constructed by
1985. Local shares and user charges only consider pre-1985
costs. Existing debt is used in calculating the user charges but
is not included in the local share.
These costs were developed from cost estimates for the Recom-
mended Alternative. They can be expected to change by the time
estimates are prepared in the design step of the construction
grants sequence. A detailed user charge scheme will be completed
as part of the Step II process. Reasons for expecting the Step
II estimates to vary from those presented in the EIS include the
following:
• Cost estimates reflect the planning stage of the process,
subsequent estimates will use more detailed cost information
appropriate to the design stage of the project.
• Costs are expressed in 4th
• Individual municipalities
ferently among their users
Quarter 1979 dollars.
may wish to allocate costs dif-
than was assumed in the EIS.
19
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• EPA's share of the funding may change or the availability of
such funds altogether may be questionable.
Due to the questionable status of future EPA funds, municipali-
ties should investigate the possibility of alternate funding
through sources such as FHA or HUD.
Wastewater Treatment
Needs
Issue 4: Several commentors questioned where existing water
quality and public health needs for wastewater improvements have
been defined and if the alternatives address these problems.
Response to Issue 4: Chapter V Draft EIS outlined the needs
documentation for wastewater management in the Study Area through
a sanitary survey, local SEO records, visits to area treatment
plants, water quality modeling, and analysis of local soil condi-
tions. These data were analyzed to determine the nature and
extent of needs in order to propose improved wastewater manage-
ment in the Study Area. A complete record of the needs analysis
may be found on pages 82 through 84 of the Draft EIS and in
Appendix 1-2 and 1-3 of that document.
The Recommended Alternative outlined here in Chapter IV proposes
centralized collection and treatment of wastewater for Segments
1-4, 7-11, 17, and 20. This wastewater management plan is
designed to solve the needs defined in this area as well as to
provide for a reasonable rate of growth. In Segments 12 through
16 and 18, insufficient needs were defined to warrant the large
capital investment of centralized facilities. This could have
been based on low population density, lack of well contamination
evidence, or the existence of large lot sizes and marginal but
appropriate soil conditions for on-site wastewater management.
These areas are proposed to continue on the use of upgraded
on-site systems with the possibility of the assistance of an
on-site management agency.
On-Site System
Feasibility
Issue 5; Several commentors have questioned the suitability of
the soils in the Study Area to accommodate on-site wastewater
treatment and think that upgrading these systems will not
adequately protect public health.
Response to Issue 5: Soil limitations for on-site systems do
exist in the Study Area. The major limiting factors cited by the
US Department of Agriculture (USDA), the Soil Conservation
Service (SCS) and the Commonwealth of Pennsylvania Chapter 73
Regulations are (1) shallow depth to bedrock, (2) shallow depth
to water bearing strata, (3) seasonal high water table (4) too
rapid or too slow a rate of permeability, and (5) excessively
steep slopes. Because of these limitations the two types of
on-site systems considered for use in the area are septic tank -
sand mound systems and holding tanks. Holding tanks were con-
sidered where soils were believed inadequate to support a sand
mound system. The assumption of using these technologies is
conservative. Site-by-site analyses may find that some on-site
systems can be upgraded with a less costly system than sand
mounds or holding tanks.
20
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A small waste flows (SWF) management District could be set up to
provide an overall framework in which on-site systems would be
properly regulated. A description of such a district is included
in Chapter IV of the Draft EIS. A SWF management district would
provide for better protection of the public health than would be
available without such an agency. The purpose of a SWF manage-
ment district is to balance the costs of management with the
needs of public health and environmental quality.
Infiltration
and Inflow Issue 6; In Gettysburg Borough, infiltration and inflow (I/I) to
existing wastewater collection systems is considered by the
Gettysburg Municipal Authority and PA-DER to be excessive. Sewer
system evaluation studies required by EPA and PA-DER for facility
planning have yet to be completed by Gettysburg Municipal
Authority and are critical in arriving at the selected plant
design for the Gettysburg STP. In light of these facts, what is
the current status of I/I studies performed by the Authority,
what remains to be accomplished, and how can I/I reduction be
estimated for purposes of this EIS?
Response to Issue 6: EPA and PA-DER met with the Gettysburg
Municipal Authority's consultant, Gannett, Fleming, Corddry, and
Carpenter, Inc. (GFCC) on April 16, 1981 to discuss I/I. GFCC
pointed out that I/I to Gettysburg STP is very significant and
believed that the actual I/I is higher than 0.5 mgd which was the
amount initially estimated and was used in the Draft Els. GFCC
was near the completion of their .second phase I/I study for GMA
and their revised estimate showed that the amount of I/I is at
least 0.7 mgd. It was decided that, with the concurrence of
PA-DER, the I/I from Gettysburg Borough will be 0.7 mgd in the
Final EIS.
Water Consumption
Issue 7: The metered water consumption in Gettysburg Borough
during the past two years has averaged 1.0 mgd, excluding fire
protection, leaks, etc. Assuming that an average of 85 percent
of this is returned to the sewer system, the present average
sanitary flow is about 0.855 mgd. The Draft EIS estimated a
sanitary flow of 0.755 mgd which is 0.1 mgd lower than the above
estimated. GMA suggested an increase of 0.1 mgd in sanitary
along with the 1/1 increase.
Response to Issue 7: EPA's design flows for Gettysburg Borough
for the year 2005 were developed by allowing 80 gallons per
person per day which is a very reasonable projected wastewater
flow considering the past history of water usage. In addition,
there is still uncertainty about the I/I from Gettysburg Borough.
This uncertainty, which is reflected by the increase of 0.2 mgd
over the initial I/I estimate, can over shadow the increase of
0.1 mgd in sanitary flow. For practical purpose, the sanitary
flow for the year 2005 will remain at 0.755 mgd.
water quality
TUtil'IFfeATIflkS;
COMMENTS AND RESPONSES
Effluent
Limitations
Issue 1: Advanced secondary effluent limitations are required by
PA-DBS' for all three STP's in the Study Area. These limitations
21
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Nutrient Limitations
restrict 5 day biochemical oxygen demand (BOD,-) and suspended
solids (SS) to 15 milligrams per liter (mg/1) ana amonia nitrogen
(NH3) to 3 mg/1 in the summer and 9 mg/1 in the winter. Based on
the modeling performed as a part of this EIS, these limitations
appear to be more stringent than necessary to protect the water
quality of Rock Creek.
Response to Issue 1; In the Draft EIS, the PA-DER effluent
limits were used as given to determine the treatment facilities
required. Appendix C is a waste load allocation which was done
as a part of the Final EIS, to evaluate the PA-DER limits and, if
possible, to derive less stringent effluent limits. The results
of the waste load allocation are summarized as follows:
Flow B0D5 NH, TP DO
STP (MGD) (mg/1) (mg/1) (mg/1) (mg/1)
Cumberland 0.17 30 3.0 3.0 5.0
Gettysburg 1.58 25 2.0 1.0 5.0
Lake Heritage 0.14 30 15.0 7.0 5.0
These results must be used with caution, however. For example,
the BOD,- limit derived for Gettysburg assumes zero bottom oxygen
demand In the vicinity of the plant. That is, the bottom sludge
blanket was assumed to disappear with the improvement of the
treatment facility. If a certain amount of aged sludge remains
and exerts some bottom oxygen demand (say 1.5 gm 0,/M2/day) in
the future, the effluent BOD, limit for the Gettysburg STP will
be reduced to 15 mg/1 in orrler to maintain a dissolved oxygen
level (DO) of 5 mg/1 in Rock Creek. Also, because of the
restriction of NH, for the Cumberland STP, an effluent with BOD5
values below the 30 mg/1 (calculated to maintain the required DO
levels in Rock Creek) can easily be met. The impact of Lake
Heritage's discharge was not evaluated for White Run, only for
Rock Creek.
In summary, the effluent requirements for Lake Heritage and
Cumberland could possibly be relaxed somewhat without affecting
the water quality of Rock Creek. The advanced secondary treat-
ment levels required for the Gettysburg STP, however, appear
justified based on the water quality modeling (see Appendix C)
and the inclusion of the bottom oxygen demand as noted above.
Issue 2: Ammonia concentrations in the effluent were not
evaluated, based on toxicity considerations.
Response to Issue 2: A mass balance calculation for ammonia
levels in Rock Creek was conducted. PA-DER requires a maximum
level of 1.5 mg/1 ammonia nitrogen in Rock Creek for toxicity
reasons. The calculation indicates that to maintain the ammonia
nitrogen level below 1.5 mg/1, these effluent limits are
required: 3 mg/1 at Cumberland, 2 mg/1 at Gettysburg, and 15.0
mg/1 at Lake Heritage. These results suggest that nitrification
process is required at these facilities.
PA-DER has placed seasonal effluent ammonia concentrations on the
facilities. From June 1 through October 31, the plants are
required to meet an ammonia limit of 3 mg/1; the remainder of the
year, the facilities should meet an ammonia limit of 9 mg/1. The
non-summer low flow for Rock Creek has been estimated as 11 cubic
feet per second (cfs) at the Gettysburg STP with a critical
22
-------
temperature of 15°C. For the temperature of 15°C and a pH value
of 7.5, the EPA Quality Criteria for Water indicates that an
in-stream ammonia level of 2.3 mg/1 would maintain a condition
that is not toxic to fish. PA-DER's effluent limits of 9 mg/1
will result in a stream concentration, for the above conditions,
of 2.4 mg/1 ammonia nitrogen. As can be seen, this will maintain
concentrations as suggested by EPA criteria.
HISTORIC AND ARCHAEOLOGIC
RESOURCE IMPACTS;
COMMENTS AND RESPONSES
Primary Visual
Impacts
Issue 1: Commentors have suggested that additional mitigative
measures be discussed for avoidance of primary adverse visual
effects of new sewage treatment facility construction on historic
sites adjacent to and within the Gettysburg Battlefield National
Historic District (e.g., construction of a new pump station on
the Cumberland Township border northwest of Business Route 15 and
expansion of sewage treatment plants such as at the Gettysburg
STP site).
Response to Issue 1: Although pump stations are generally one-
story structures of small size, they frequently are constructed
in a style which is not compatible with the surrounding architec-
ture. They are often sited in open areas and surrounded by
hurricane fences with negative aesthetic quality. Therefore, the
presence of such structures adjacent to historic buildings and
districts constitutes a negative adverse visual effect on these
resources. Sewage treatment plant expansion which requires
construction of additions to the physical plant may increase
visual degradation of the Historic District. The Gettysburg STP,
at present, is in a low lying wooded floodplain of Rock Creek and
not readily visible from Gettysburg National Military Park focal
interpretive points (Figures 1 and 2 as attached in Appendix D
update). It is, however, adjacent to the Benner Hill Section of
Gettysburg National Military Park. Expansion at the Gettysburg
site could result in primary adverse visual effects. An existing
house on Benner Hill is not compatible in style with the sur-
rounding architecture and pastoral vistas and creates a visual
intrusion. This house is readily visible from Culp's Hill
(Figure 1), is more noticeable than the Gettysburg STP, and
lessens the visual integrity of the area. Nevertheless, any
development or construction activity in the area should be under-
taken with extreme care so as not to further affect visual
values.
Mitigation measures to alleviate potential primary adverse visual
impacts from new wastewater treatment facilities to be erected as
part of the Recommended Alternative are presented in Chapter V.
Mitigative measures are discussed in the DEIS and Appendix E
included in this document. The process by which these measures
will be implemented in specified in Chapter V, describing MOA
provisions.
Primary Archaeological
Impacts
Issue 2; The Advisory Council on Historic Preservation has
pointed out that Dr. Kinsey's preliminary survey of the Rock
Creek interceptor route, proposed for the Regional 201 Wastewater
23
-------
Treatment Facilities Plan, was corridor specific and preliminary.
In addition, it appears that only prehistoric sites were con-
sidered by Kinsey. The Advisory Council states that if areas of
the Rock Creek drainage determined by Kinsey to have "low"
archaeologic potential will be disturbed by construction related
to the selected alternative, an additional survey should be
conducted in these areas to test Kinsey's model. The Council
indicates that detailed intensive archaeological survey and
testing will be necessary when an alternative is chosen. "This
should include 100% survey of interceptor corridors, treatment
plant expansion areas, and pumping stations [sites] along with
subsurfaces testing. Survey and testing should be scheduled as
early as possible during Step II, so that there will be enough
time for results to be taken into account both in line alignment
and in carrying out any necessary mitigative activities."
Response to Issue 2: The presence of significant historic and
archaeological resources which may be adversely affected by
construction of the proposed wastewater treatment facilities
(i.e., primary impacts) is pointed out in the Draft EIS on pages
58, 60, 62, and 63. The lack of professional reconnaissance of
areas, other than Rock Creek, which may be adversely affected by
construction of alternatives is pointed out on page 128; and the
need for a full-scale archaeological survey of the selected
alternative prior to construction is discussed on pages 128 and
130. As specified in the MOA (Chapter V), a comprehensive
archaeological survey will be conducted to identify both historic
and prehistoric archaeological resources which may be disturbed
by construction of the selected alternative. Such survey will be
conducted as early as possible during step II. In accordance
with the Advisory Council's recommendation, any areas to be
affected by construction, which were determined by Kinsey to have
"low" archaeological potential and require no further survey,
will be included in the comprehensive archaeological survey. The
comprehensive archaeological survey will systematically investi-
gate 100% of the primary impact areas (areas to be disturbed by
construction). These areas include interceptor corridors, treat-
ment plant expansion areas, land application areas, and pump
station sites. Such survey will provide both a test of Kinsey's
model, and generation of additional systematically collected data
which may provide a data base for formulation of future predic-
tive models.
Secondary Effects
Issue 3: The language in the DEIS which states th.it existing
historic preservation legislation provides for "consideration of
primary effects on historic cultural resources", but continues
with "such consideration would not be required for privately
funded future development (secondary effects) in the planning
area" (DEIS, p. 135) was questioned and asked to be rectified.
It was also pointed out that consideration of mitigative measures
by EPA to avoid adverse indirect impacts of EPA-funded projects is
mandated by historic preservation legislation and by NEPA.
Response to Issue 3: The intent of the statement has been mis-
interpreted (DEIS, p. 135). To clarify the meaning of that
statement, the fifth paragraph on page 135 should be reworded to
read as follows:
"Federal cultural resource protection legislation does not and
is not empowered to require private developers to consider the
effects of project-related development occurring after instal-
lation of the EPA-funded facilities on the historic/aesthetic
integrity of the area. However, EPA is charged with responsi-
24
-------
bility for considering the effects of a secondary impact, such1
as future project-related development, on cultural resources,
it is difficult, however, for EPA alone to implement controls
on future development in the absence of any local land devel-
opment regulations. EPA may deny a construction grant, but
does not have the power to enforce controls over future devel-
opment which occurs if the construction grant is approved. A
mechanism would be required for implementing and enforcing
local controls on future land development.
Federal historic preservation legislation requires that when a
Federally-funded project will have an unavoidable adverse
effect on significant cultural resources, a Memorandum of
Agreement (MOA) to mitigate such adverse effects should be
executed between the Executive Director of the Advisory
council, EPA and the state Historic Preservation Officer,
prior to awarding a Step II constructon grant. In order to
formulate an MOA which can be successfully administered,
however, both legislative sanctions (state or local) and the
cooperation of local officals are necessary."
Such mitigative measures and a proposed Memorandum of Agreement
are discussed in Chapter v.
issue 4: it has been point out that Appendix G-8 (the Advisory
Council's A Plan to Preserve the Historic Resources of the
Gettysburg Area of the Commonwealth of Pennsylvania) Ti missing.
Response to Issue 4: Appendix G-8 is included in the Final EIS
(Appendix D).Specific reference is made to page 33 (Items 1, 2,
and 3); page 34, paragraph 4; and page 37, paragraph 2 for
examples of mitigation alternatives which are applicable to the
present project. This ACHP document provides excellent back-
ground discussion of the cultural values, including aesthetics,
characterizing the Gettysburg area, potential impacts, and miti-
gative measures which should be considered when actions are
contemplated.
Secondary Impacts on
Historic/Archaeoloqic
Resources
Issue 5a: Both the Advisory Council on Historic Preservation and
the National Park Service requested clarification of the discus-
sion of potential indirect impacts of the project on archaeologi-
cal, historic and aesthetic resources. Specific reference was
made to the statement (pages 130, 135), "none of the alternatives
would induce growth or development beyond that which would occur
without the proposed Federally-funded project." It was requested
that a better discussion be provided of "where population will
tend to cluster under each alternative."
Response to Issue 5a; Baseline growth has been used to design
the various elements of various wastewater treatment facilities
proposed in the alternatives. Nevertheless, construction of
these EPA-funded projects can be anticipated to alter the amount
and distribution of future growth in degree, between municipali-
ties, and within municipalities (between segments). Rate of
growth also may be affected. All of these types of induced growth
effects constitute secondary or indirect impacts. Areas where
induced growth impacts may be concentrated as a result of imple-
mentation of the project consist of Segments 4, 7-11, 17 and 18.
25
-------
The following discussion summarizes the projected future growth
configurations under each revised alternative (Chapter VI of the
Draft EIS). This information is also discussed under Existing
Conditions; Issue 1; Table III-l summarizes the data presented
below. Figure III-l illustrates the future land development
pattern anticipated by the year 2005. Differences between the
various alternatives are at most modest and relate to shifts
among Segments 4, 17, and 18.
Under Alternative A, the projected growth configuration would be
the same as that for future baseline growth which would occur by
the year 2005 if the EPA funded wastewater treatment project were
not constructed. Generalized future growth projections for each
segment of Alternative A are as follows:
Segment No
Population
Dwelli:
1
662
305
2
0
0
17
1,207
431
18
899
320
3
118
42
4
166
59
5
14
5
6
107
38
7
14
5
8
236
84
9
229
76
10/11
382
125
20
3
1
Growth configurations in Segments 16, 12, 15, 14, 19, and 13 are
related to correction of on-lot systems, and will not be dis-
cussed among secondary impacts of the proposed EPA-funded waste-
water treatment facility.
Implementation of Atlernative B would result in a growth and
development pattern similar to that of Alternative A, except that
420 fewer people can be expected in 150 fewer dwelling units in
Segment 17. Segment 18 would serve only 599 persons in 199 pro-
jected dwelling units. Development would shift to Segment 4
along Route 30, where projected population growth of 927 persons
would be contained in 330 dwelling units.
Construction of Alternative C would result in a growth pattern
similar to Alternative A.
Under Alternative D, there would be a reduction in the population
projected for Segment 18 in Alternative A or baseline growth,
from 899 persons in 320 dwellings units to 604 persons in 215
units. Segment 4 would serve a population of 461 persons in 104
dwelling units, an increase over Alternative A of 295 persons in
105 dwelling units. Remaining growth configurations in the Study
Area would remain the same for Alternatives A and D.
If Alternative E were implemented, there is expected to be a
reduction in growth projected for Segments 17 and 18 under
Alternative A and an increase in Segment 4. Projected population
in Segment 17 would be reduced to 812 persons and dwelling units
would be reduced to 290. In Segment 18, a projected population
of 604 persons would be located in 215 dwelling units; whereas
257 persons in 308 units are anticipated in Segment 4. There
would be less development in the Lake Heritage area (Segments 7,
26
-------
FUTURE RESIDENTIAL
FIGURE III-l
FUTURE LAND USE BASELINE 2005
-------
8, 9, 10, 11) and more in outlying areas of Mount Joy, resulting
in an increase of 13 7 persons in 48 dwelling units in this out-
lying area in contrast to Alternative A. There would be an
increase of 135 persons in 48 units in Segment 7 near the US-15
interchange and a reduction of 282 persons in 95 dwelling units
elsewhere in Lake Heritage.
The Recommended Alternative would not result in a growth confi-
guration significantly different than baseline conditions pro-
jected in the majority of the study area. In Straben Township,
the Alternative will result in a gain of 420 people and 150
dwelling units in Segment 4. Also on internal redistribution of
340 people and 21 dwelling units will occur between Segment 18 to
Segment 4. This will result in a total increase in Segment 4 of
761 people and 271 dwellings units above baseline conditions
projected.
Mitigation of Issue 5b: If the proposed EPA-funded project affects the confi-
Indirect Impacts guration and clustering of future growth, would EPA be re-
sponsible for consideration of indirect effects of project-
related future development on archaeological, historic, and
aesthetic resources.
Response to Issue 5b: It is anticipated that after selection of
the Recommended Alternative, an achaeological survey will be
conducted of all areas where indirect effects of construction of
the alternative are expected to occur. Such a survey may consist
of background studies, development of a predictive model, pede-
strian reconnaissance, shovel tests, and other investigations to
test the predictive model. Results of the survey would provide
an inventory of the historic and prehistoric resources to be
affected by future growth related to the selected alternative,
and would assist with future planning. Provision necessarily
should be made for mitigation of unavoidable adverse indirect
effects of the preferred alternative on archaeological resources
listed on or determined eligible for the National Register of
Historic Places. An archaeological survey of areas to be in-
directly affected by construction of the selected alternative has
been requested by the Pennsylvania Historical and Museum Commis-
sion (Verbally, Mr. William McClaughlin, Pennsylvania Historical
and Museum Commission, Office of Historic Preservation, at
WAPORA, Inc., on 8 April 1981).
EPA also is be responsible for consideration of indirect effects
of the project on historic and visual resources. The potential
adverse indirect effect of the project on historic and visual
resources of the Gettysburg area is discussed under responses to
Issue 6 (a request by the National Park Service for additional
work to assess the potential indirect adverse impacts of the
project on the integrity of views from additional focal points
within the Gettysburg National Military Park). Indirect effects
on historic resources from induced growth pertain primarily to
alteration of the overall scenic historic setting of historic
structures and districts; therefore, the assesssments of indirect
impacts on historic resources basically are the same as those for
indirect impacts on visual resources. Indirect effects on his-
toric resources also include those impacts resulting from sewer-
related development, resulting in conversion/demolition of his-
toric structures and sites to other uses. These impacts are not
expected to be widespread in the Study Area as the result of any
of the proposed alternatives. There are, however, select identi-
fied historic sites listed in the DEIS inventory (Figure III-9,
DEIS, p. 59 and Appendix G-2) and located in Segment 4 which may
be subjected to increased development pressure in Alternatives B,
28
-------
D, and E as the result of induced growth. the manner in which
these impacts are to be mitigated is discussed in Chapter V.
Aesthetic Impacts
Issue 6; The National Park Service requested that the aesthetic
section of the DEIS be improved by considering additional signi-
ficant view points as seen from the Battlefield tour route and
historic routes entering Gettysburg. They requested additional
analysis of the anticipated future development on significant
views of the Park and National Register District. Improved
graphics which show the relationship between segments and the
Park and Historic District areas were also requested.
Response to Issue 6: To comply with the NPS request for addi-
tional analyses of indirect impacts on aesthetics and for consi-
deration of additional views from focal points within the Park,
additional fieldwork was conducted on April 12 and 13, 1981.
This fieldwork adds to Appendix G-7 which documented views from
28 different stations shown on Figure 111-11 (DEIS p. 63). All
photographic inventory work has been directed into those areas
where cultural and aesthetic values are presumed to be signi-
ficant (i.e., the National Register Historic District) in combi-
nation with those areas of direct and indirect impact relating to
potential EPA sewering actions (i.e., those segments to be
sewered in the Recommended Alternative).
In order to document potential adverse indirect effects of the
EPA-funded project on the Gettysburg National Military Park and
the National Register Historic Distric, a series of views and
panaoramas was photographed from strategic focal points within
the Gettysburg National Military Park (Figure II1-2 revised).
Additional views selected were guided by DEIS comments and by Mr.
Thomas Harrison, NPS Historian, who also provided the list of
visual features (aesthetically compatible and incompatible) which
are visible from these stations (Table III-2) and an estimate of
viewsheds from these focal points. Figure II1-2 has been revised
and updated from Figure 111-11 in the DEIS (p. 65) and documents
the most vital focal points in the Park and in the National
Register Historic District. Again, the stations mapped are keyed
to Appendix D (revised DEIS Appendix G-7) where the views them-
selves are shown and classified as to type of view and quality of
view. Figure 111-3 takes the view data another step and makes a
determination regarding extent of viewshed relating to the major
cultural values such as Oak Ridge, the Peace Memorial Drive,
Barlow's Knoll, Benner Hill entrace, Culp's Hill, and East
Cavalry Battlefield. This delineation of viewsheds was developed
as the result of topographic analysis, fieldwork, and picture
analysis as well as extended conversations with National Park
Officials at Gettysburg. Also, on Figure II1-3, all areas or
segments proposed for sewering by EPA in all of the alternatives
have been represented. The interaction or overlay of the pro-
posed sewering and the viewshed representations is basis for
indirect visual impact analysis. In summary, Figure II1-3
indicates those areas where significant adverse visual impacts
can be expected as the result of additional development induced
by provision of public sewers.
More specifically, important focal points in and adjacent to the
park and National Register Historic District include Barlow's
Knoll, the entrance to Benner Hill, the Route 116 entrance to the
East Cavalry Battlefield Site, and Culp's Hill. Figures 1, 2, 3,
and 4 (Station 12, Appendix D) depict views in a 360° panorama
29
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ASF.e
VIEW TYPE'
COMPATIBLE
INCOMPATIBLE
LAND USE1
a NATURAL
b AGRICULTURAL
c RESIDENTIAL
o COMMERCIAL
e INDUSTRIAL
f MONUMENTAL
*• PHOTOGRAPHIC STATION
\
DIRECTION OF PHOTOGRAPHIC
VIEW
V
FIGURE III—2
SCENIC VIEWS FROM PHOTOGRAPHIC I
STATIONS IN GETTYSBURG NATIONAL HISTORIC
DISTRICT
SOURCE FIELD SURVEY (WAPORA)
-------
Table III-2. Landmarks, Compatible Features, and Intrusions Visible from Oak Ridge Observatory,
Peace Nemorial Drive, and Barlow's Knoll and Culp's Hill (Mr. Thomas Harrison, NPS).
Locations are keyed to revised Figure III-II. (C = compatible, I = incompatible)
Oak Peace Barlow's Culp's
Ridge Memorial Knoll Hill Visible Features Quality of Features
Station Station Station Station
29 30 12 36
Route 34
C and
X
Westinghouse Plant - post 1968
C
X
Keckler's Hill and mountains (off map)
C
X
X
X
Farms on Table Rock Road
C
X
X
X
Houses on Route 34 and blue bldg.
I
X
James Gettys. School - post 1968
C and
X
Farms and houses Bus. Rt. 15
C and
X
X
High lands
I
X
X
Twin Oaks Subdivision - post 1968
I
X
X
Interchange Overpass Rt. 15 and 30
- post 1963
I
X
X
X
Mobile Home Park - post 1963
I
X
Houses on Rt. 116
C and
X
X
Benner's Hill (Park)
C
X
X
X
House on Benner's Hill (Park) -
post 1963
I"
X
X
X
X
Wolfe's Hill
c
X
X
X
Culp's Hill (Park)
C
X
Park Tower on Culp's Hill (Park)
N. A.
X
X
X
X
National Tower - post 1963
I
X
Big Round Top (Park)
C
X
X
Unfinished Holiday Inn (7 stories)
I
X
X
X
X
College
C and
X
X
X
Radio Tower
I
X
X
Ford Agency
I
X
Sheep's Heaven
C
X
High School
I
X
X
X
Peace Memorial
C
X
X
Cobean Farm
c
X
House on Oak Hill
c
X
Bank
I
X
Shopping Center
I
X
X
Woods screening view north
C
-------
r
FIGURE H-3
POTENTIALLY IMRACTED
AND VISUAL RESOURCES IN THE
GETTYSBURG STUDY AREA
HISTORY
GENERALIZED VIEWSHEDS FROM NPS
HOLDINGS /NATIONAL REGISTER
HISTORIC DISTRICT FOCAL POINTS
POTENTIALLY SEWERED AREAS BY
SEGMENT (ALL ALTERNATIVES)
SOURCE THOMAS HARRISON, NATIONAL PARK SERVICE. GCTTYS
-------
from Barlow's Knoll. The view southeast is degraded by the
present King's Supermarket development (Figure 5). Areas to the
north are screened by a dense stand of trees, and several visual
interruptions occur in views to the south and southwest. Future
development, which would be most intense under Alternatives A and
c, however, potentially may degrade views to the north on the
west side of Business Route 15 (Segments 17 and 18). On the
other hand, Alternatives B, D, and E would provide greater con-
centration of growth in Segment 4 along Route 30, which may
further degrade views from Culp's Hill (Figure 1, Station 36) and
from the entrance to Benner Hill (Figure 1, Station 8, Figure 1,
Station 10). By and large the Route 30 area (Segment 4) is
relatively removed from important focal points and already is
substantially degraded in terms of visual consistency with the Park
setting.
In terms of the Lake Heritage area, views from the Route 116
entrance to the East Cavalry Battlefield (Figure 1, Station 31;
Figures 1, 2, and 3, Station 35) and from other areas within the
East Cavalry Battlefield holdings indicate that areas surrounding
the East Cavalry Battlefield site are vulnerable. These adjacnet
areas were shown as "critical areas" in the Advisory Council's
1977 report (Figure II1-4) where some sort of Federal control was
to recommended by ACHP. In the same report, however, the
Advisory Council did not map areas around the East Cavalry
Battlefield as especially important from a visual perspective.
In the National Park Service's General Management Plan, a zone
surrounding the East Cavalry Battlefield site also has been
designated as a "critical area land that if developed, would have
visual impact on the park" (Figure IXX-4). Under all Alterna-
tives, additional development can be expected to occur at Lake
Heritage. Development adjacent to Route 116 would be visible
from the entrace of the East Cavalry site (Figure 1, Station 37;
Figure 1, station 34), from General Custer's Memorial (Figures 1,
Station 32) and from sections of Route 116 which are within the
National Register Historic District. Future growth also can be
expected to intrude into the National Register Historic District
in the vicinity of Lake Heritage (Segments 6 and 9); however,
such development would not be visible from Station 3, wiithin the
East Cavalry Battlefield site (Figure 1). Furthermore Lake
Heritage is an existing subdivision where development can be
expected to remain at low densities and be of a low-rise resi-
dential character in the future. Viewshed impacts in the Lake
Heritage area, in sum, are limited in areal extent and not
potentially severe.
For the purpose of illustration, hypothetical massings of poten-
tial development which may occur as the result of sewering in
Alternatives A-E have been sketched onto photographic enlarge-
ments of specific views (Figures III-5 and III-6). These figures
were prepared to indicate hypothetically "worst case" or incom-
patible development possible in each alternative. Though not
actually proposed, a commercial hotel structure or elderly
housing or college dormity all could take the form of a 6- to
8-story mid-rise structure and appear as shown in Figures II1-5
and II1-6. in addition to sheer mass to height of structures,
issues such as color, texture, building lines, signing, etc. also
are determinants of incompatibility. These building-related
issues can be expected to be important concerns in the future
development of Segments 17, 18, 4, and the Lake Heritage area.
Figures 111-5 and 111-6 indicate the type of impact that could
result in those areas identified in Figure II1-3.
33
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GETTYSBURG
PM FEDERAL LAND
m AUTHORIZED ACQUISITION
WMk CRITICAL AREAS
2,000
FIGURE III—4
AREAS DESIGNATED AS CRITICAL BY ACHP (ACHP 1977)
34
-------
FIGURE 111-5. HYPOTHETICAL SECONDARY VISUAL IMPACT IN AREAS
TO BE SEWERED
-------
FIGURE 111-6. HYPOTHETICAL SECONDARY VISUAL IMPACT IN AREAS
TO BE SEWERED
-------
Of special concern are the vacant institutional lands north of
Gettysburg Borough (Figure II1-6 in the DEIS) which currently
constitute open space but which potentially may be developed if
additional sewage capacity is provided. These vacant institu-
tional lands happen to be contained within viewsheds depicted on
Figure II1-3 and are especially important to maintaining the
value of the viewsheds. Because institutions are permitted to
erect buildings with heights of eight stories (in the Borough)
and because these institutions are more prone to large-scale
construction with taller structures, institutional lands adjacent
to the Park are especially critical. In Appendix D, Figures 1
and 2, Station 29; Figure 2, station 30 institutional land have
been photographed; development on these lands would constitute an
indirect visual impact on views from Oak Ridge Observation Tower,
Barlow's Knoll, and Peace Memorial Drive. Although Gettysburg
College and the other relevant institutions indicated that they
have no plans for expansion; future land exchanges, changes in
sewage treatment allocation, future hook up arrangements, etc.
may conceivably result in further development of institutional
lands in the future.
Mitigation of these potential adverse effects on the Oak Ridge
viewshed, the Peace Memorial Drive viewshed, Barlow's Knoll
viewshed, Benner Hill viewshed, Culp's Hill, and the East Cavalry
Battlefield viewshed are discussed in Chapter V.
37
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CHAPTER IV
Final Evaluation of Alternatives
-------
CHAPTER IV.
FINAL EVALUATION
OF ALTERNATIVES
INTRODUCTION
In recommending wastewater service alternatives to be funded by
the Agency, EPA has considered individual and cumulative environ-
mental effects, cost-effectiveness, public and governmental
agency preferences, and potential for successful implementation.
Based upon this evaluation, EPA revised the Alternatives pre-
sented in the Draft EIS to formulate a Recommended Alternative
that is described in this section.
Municipal Preferences
Of the local communities which have participated in the EIS
process, three communities registered specific preferences on the
selection of alternative wastewater service systems. These local
communities are Cumberland Township, Straban Township, and Lake
Heritage.
Cumberland Township recommends adoption of Alternative D. This
conclusion was reached after a careful review by the township of
the five alternatives set forth in the Draft EIS. Some refine-
ments of Alternative D were made to meet the interests of
Cumberland.
Straban Township expressed a willingness to support Alternative B
with the provision of sufficient treatment capacity reserved for
Segment 4.
Lake Heritage Municipal Authority with the concurrence of the
property owners endorsed Alternative E which would provide sewer
to the area. With significant growth projected in the next 20
years, it is their belief that low pressure collection and cen-
tralized treatment is the most reliable and best overall solution
for the area.
Environmental Impact
Considerations
The environmental impacts of the alternative systems have been
summarized in Chapter II. As the public comments in Chapter III
indicate, questions involving environmental impacts centered upon
these specific effects:
• historic and archaeologic impacts
• population projections and induced growth
• surface water quality impacts
• cost-effectiveness.
Based on these comments, a Memorandum of Agreement has been
drafted to protect the historic and archaeologic resources of the
area, and design modifications have been made to mitigate other
impacts identified.
Alternative Recommended
by EPA
The Recommended Alternative for the Study Area is shown in Figure
IV-l. Components of the Recommended Alternative are taken from
the various alternatives evaluated in the Draft EIS.
59
-------
o
GETTYSBURG^
I ri
|
\r
\
\
$>
\ SEGMENT
/ 1,3,4,18
/ PLANNING AREA BOUNDARY
SEGMENT BOUNDARIES
18 SEGMENT NUMBER
WASTEWATER CONVEYANCE ROUTE
SEWAGE TREATMENT PLANT (STP)
SERVED BY
GETTYSBURG STP
CUMBERLAND STP
7,8,9,10,11,20 NEW LAKE HERITAGE STP
f-
0
MILE
FIGURE IV-1
RECOMMENDED ALTERNATIVE
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Each municipality and EPA individually considered the advantages
of the Draft EIS alternatives and compared these to the
associated costs. Through this process, the Recommended Alter-
native was derived. The alternatives in the Draft EIS from which
the recommended alternative was derived are shown in Table IV-1
along with the segments served by sewers.
Table IV-1. Components of the Recommended Alternative
Most similar
Alternative in
Segments
Municipality
Draft EIS
sewered
Gettysburg/Straban
B
1,3,4
Cumberland
D
2,17
Lake Heritage
E
7-11,20
Gettysburg
Borough
For Gettysburg Borough, the wastewater treatment and service
system proposed in various Draft EIS alternatives present in-
significant differences in user charges and environmental impacts
among these alternatives. They all are considered to be environ-
mentally sound, cost-effective, and readily implementable. The
Borough of Gettysburg did not formally state its preference for
any specific alternative. All alternatives for Gettysburg in-
cluded upgrading the existing STP to serve Segments 1 and 3. The
alternatives evaluated included the options of serving or not
serving Segments 4, 17, and 18 (Straban Township). EPA recom-
mends Alternative B which calls for upgrading and expansion of
the existing facilities to serve Segments 1, 3, and 4 and treat
the holding tank waste from Segment 18.
Straban
Township
EPA recommends Alternative B to serve Straban Township with some
increase in treatment capacity at the Gettysburg plant in order
to meet the future growth and sewage disposal needs in Segment 4
along Route 30. Segment 18 is not sewered in this alternative,
but holding tank waste from this segment will be treated at the
Gettysburg treatment plant.
Cumberland
Township
The Recommended Alternative for Cumberland iB the same as Alter-
native D in the Draft EIS. This alternative consists of upgrad-
ing the existing treatment plant to serve Segments 2 and 17 and
has been endorsed by Cumberland Township. As on-site systems are
not recommended for this area, the Cumberland STP is not expected
to treat any holding tank waste.
Lake Heritage
The wastewater service problems (particularly holding tank and
septic tank failures) of Lake Heritage area have been the focus
of considerable attention in the EIS process. The alternatives
available for Lake Heritage are either continued use of a ocnbinatian of
holding tanks and cn-site systems or centralized collection (pressure sewers)
and treatment.
41
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Conventional on-lot disposal systems are unsuitable in many parts
of the area due to limited permeability of soils and other fac-
tors. Holding tanks have numerous problems, particularly after
storms. Although improvement of on-site systems is more cost-
effective in terms of present worth, the above factors outweigh
the present worth. As a result, EPA recommends centralized
treatment for Lake Heritage by sewering the area. This recom-
mendation corresponds to Alternative E in the Draft EIS. Seg-
ments served in this alternative include 7-11, and 20. Federal
funding of 85% for pressure sewers is a factor in making user
charges more competitive with on-site treatment alternatives.
In summary, under EPA's recommended alternative, Cumberland
Township will retain its north plant and expand it to accomodate
future growth in Segments 2 and 17. The existing Gettysburg STP
will be expanded to serve the Gettysburg Borough (Segments 1 and
3) and Segments 4 and 18 (holding tank waste only) of Straban
Township. The Lake Heritage STP will serve Lake Heritage resi-
dents (Segments 7-11 and 20). The Lake Heritage STP will also
treat holding tank waste from Segments 12 and 14-16. Table IV-2
summarizes the wastewater management proposed for each segment in
the Recommended Alternative.
Table IV-2. Wastewater Management in the Recommended Alternative
Decentralized
Centralized
Treatment
Segment
treatment
treatment
facility
1
X
Gettysburg STP
2
X
Cumberland STP
3
X
Gettysburg STP
4
X
Gettysburg STP
7
X
Lake Heritage STP
8
X
Lake Heritage STP
9
X
Lake Heritage STP
10
X
Lake Heritage STP
11
X
Lake Heritage STP
12
X
Lake Heritage STP
14
X
Lake Heritage STP
15
X
Lake Heritage STP
16
X
Lake Heritage STP
17
X
Cumberland STP
18*
X
Gettysburg STP
20
X
Lake Heritage STP
* Part of Segment 18 will be accommodated by septic systems
wherever soil conditions allow. The remaining portion of
this segment will be served by holding tanks whose flows will
be treated by the Gettysburg STP.
A detailed breakdown of wastewater flows from each segment and
the treatment capacity at each plant are summarized in Table
IV-3. The sewage treatment plant capacities are 0.17 mgd, 1.58
mgd, and 0.15 mgd for Cumberland STP, Gettysburg STP, and Lake
Heritage STP, respectively.
The prospective grantees {Gettysburg, Cumberland, and Lake Heritage) will have
discretion in selecting treatment methods presented in the Draft EIS, provided
that the treatment processes are capable of achieving the effluent limits pre-
scribed by Pennsylvania DER.
42
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Table IV-3. Wastewater Flows (mgd) for the Recommended Alternative
Treatment Segment
plant
No.
Sewage
I/I
Total
Cumberland
2
17
0.051
0.088
0.015
0.013
0.066
0 .101
0.167
Gettysburg
1 & 3
4
18
0.755
0.102
0.014*
0.700
0.008
1.455
0.110
0.014
1.579
Lake Heritage
7-11, 20
12, 14-16
0.137
0 .003 +
0.003
0.140
0.003
0.143
* Indicating the sewage flow from holding tanks in Segment 18.
+ Indicating the sewage flow from holding tanks in these
segments.
Cost of Recommended
Alternative
A cost-effectiveness analysis for Alternatives A through E is
presented in the Draft EIS. The cost analysis was a factor in
the alternatives recommended for each municipality. A summary of
the costs for the recommended alternative is presented in Tables
IV-4 through IV-8. Capital, 0 & M, and salvage values are shown
in Tables IV-4, IV-5, and IV-6, respectively. The total present
worth is shown in Table IV-7 and local share and user charges are
shown in Table IV-8. Only costs that are anticipated to occur
prior to 1985 are included in the tabulation of local share and
user charges. A more detailed presentation of these costs can be
found in Appendix F. All costs (except user charges) are ex-
pressed in 4th quarter, 1979 dollars x 103.
Table IV-4. Capital Costs of Recommended Alternative
(in Thousands of Dollars, 4th quarter 1979)
Project
On-site
system
Sewer
system
I/I
reduction
Sewage
treatment
Total
Cumberland
Gettysburg
Lake Heritage
* Oornnon-t- 1 O
-0-
808.2*
510.5+
3,168.5
3,015.5
5,430.5
38.2
968.8
-0-
417.0
3,440.0
301.0
3,623.7
9,232.5
6,242.0
+ Segments 12, 14-16, 20.
Table IV-5. Annual 0 & M Costs of Recommended Alternative
(in Thousands of Dollars, 4th quarter 1979)
Proiect
On-site
systems
Sewer
system
Sewage
treatment
Total
Cumberland
Gettysburg
Lake Heritage
* Conn>Ar.+- 1 O
-0-
39.6*
18.9+
7.1
38.3
79.2
46.0
264.0
38.0
53.1
341.9
136.1
+ Segments 12, 14-16, 20.
43
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Table IV-6. Salvage Value of the Proposed Projects
(in Thousands of Dollars, 4th quarter 1979)
On-site Sewer Sewage
Project systems system treatment Total
Cumberland -0- 1,462.4 69.0 1,531.4
Gettysburg 331.7 1,391.8 658.0 2,381.5
Lake Heritage 204.8 1,383.2 69.0 1,657.0
Table IV-7. Total Present Worth by Project
(in Thousands of Dollars, 4th quarter 1979)
Present
Project Capital 0 & M Salvage worth
Cumberland 3,623.7 557.1 (386.7) 3,794.1
Gettysburg 8,232.5 3,587.2 (601.3) 11,218.4
Lake Heritage 6,242.0 1,428.0 (418.4) 7,251.6
Table IV-8. Local Share and User Charges for the Recommended
Alternative
_________
Project $1,000 User charges
(Segments) (4th Quarter, 1979) $/yr.
Gettysburg (1, 3) 1,074.7 109
(4, 18) 449.8 *313
Cumberland (2, 17) 119.8 332
Lake Heritage (7-11, 20) 818.1 568
(12, 14-16) 32.5 126
* Assumes no difference in user charge between Segments 4 and 18.
Straban may wish to allocate these differently since Segment 4
is sewered and segment 18 is not sewered.
On-Site Systems Solution of the area's concentrated water pollution problems
through the centralized alternative described above does not diminish
the importance of dealing effectively and quickly with the
scattered, but serious on-site system malfunctions elsewhere.
Proceeding with the recommended sewered projects for certain segments
should not detract from efforts to achieve long-term sanitation and
water quality objectives in the remainder of the planning area.
Although the Clean Water Act of 1977 provides economic incentives to
improve rural wastewater management by making repair and upgrading
of on-site systems eligible for 85% Federal grants, the isolated,
immediate needs in the area would be most expeditiously resolved
without grant processes by inspections and enforcement actions
conducted by Sewage Enforcement Officers (SEO's) and by owner
funding of appropriate repairs.
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Long-term sanitation and water quality objectives could also be met
without grant processes. This could be achieved first by adoption
of local ordinances to require monitoring and periodic inspection
of on-^te systems and to allow access to individual on-site systems
for inspection and maintenance. It could also be achieved by
sufficient appripriations for additional skilled personnel to carry
out the inspection, monitoring, and maintenance. For the reason
that this additional effort has not traditionally been provided here
or elsewhere, costs and manpower cannot be accurately estimated.
Services provided could be:
o Lot inspection and resident interview every three years to detect
problems with surface malfunctions and plumbing backups and to
educate residents in the proper use of their systems.
o Periodic well water sampling from properly constructed wells in
representative locations
o Emergency septic tank pumping
o Routine septic tank pumping once every three years
o Professional consultation and design recommendations,for problem
systems.
These services would supplement the present regulatory functions of
municipal SEOs.
The benefits of applying for Federal and State grant assistance to
initiate such a program can be seen as:
o Initial planning, site analysis of existing problems and develop-
ment of the management structure would be completed in an orderly
manner and at relatively low costs to the municipalities
o Repair and replacement of malfunctioning systems would cost the
homeowner a fraction of the total cost(applies only to homes
built before December 1977)
o Public participation requirements would insure citizen input to
the development of the management structure.
45
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CHAPTER V
Protection of Historic Resources
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CHAPTER V.
PROTECTION OF HISTORIC
AND ARCHAEOLOGIC RESOURCES
Remaining As indicated in the previous chapters, a Recommended Alternative
Impacts has been chosen based upon its merits as the most cost-effective,
environmentally sound wastewater management plan for the area.
However, in spite of design measures that significantly reduce
impacts, this EIS shows adverse impacts could occur with the
construction and operation of the proposed alternative. Impacts
identified include primary, construction-related disruption of
historic and archaeological resources, and design of collection
and treatment facilities that could conflict with the surrounding
historic landscape. In addition, induced growth, that which
would be drawn from surrounding areas as a result of excess
collection and treatment capacity, may impact the setting of the
Gettysburg National Military Park.
In order to mitigate these impacts, an interagency coordinating
group has drafted a Memorandum of Agreement (MOA) in compliance
with Federal Regulations outlining measures that when executed
will reduce these impacts to acceptable levels. The interagency
coordinating group was comprised of representatives from EPA, the
National Park Service (NPS), the Advisory Council on Historic
Preservation (ACHP), the Gettysburg Municipal Authority (GMA),
the Pennsylvania Department of Environmental Resources (PA-DER),
and the Pennsylvania State Historic Preservation Officer (SHPO).
The "Memorandum of Agreement" is a formal agreement between EPA,
NPS, 2CHP, and the SHPO. This agreement outlines the measures that
will be taken to preserve the historic and archaeological re-
sources of the Gettysburg area in relation to Federally funded
wastewater treatment facilities,
The project history leading to this draft MOA begin with the
facility Plan submitted to EPA for construction grant funding by
the Gettysburg Municipal Authority (GMA). In order to serve a
large projected regional population, the Facility Plan proposed
construction of an interceptor along Route 97 and Rock Creek to
a new 2.5 mgd facility near Route 15 and Rock Creek. Prior to
making any grant awards, independent requirements of the National
Historic Preservation Act (NHPA) had to be addressed. Federal
regulations under this Act, administered by the Advisory Council
on Historic Preservation (ACHP), describe procedures to be
followed if a Federally funded project will affect a site listed
on the National Register of Historic Places.
Legislative Basically, the requirements under 36 CFR Part 800, the Archaeo-
Requirements logical and Historic Preservation Act of 1974 (P.L. 93-291),
Section 106 of the National Historic Preservation Act of 1966 (P.
L. 89-665), and Executive Order 11593 "Protection and Enhancement
of the Cultural Environment" dictate a stepwise procedure to
establish what the effects of Federally assisted or licensed
projects are on cry property listed on the National Register of
Historic Places. This requires a consultation among appropriate
agencies to identify resources listed or eligible and establish
what effect the project will have. Upon finding of adverse
impact as in this case, a preliminary case report is required for
ACHP and the SHPO to comment on impacts identified. Upon review
of the case report, all parties must consider prudent and
feasible alternatives which may avoid impacts If agreement is
achieved on an action that will mitigate impacts defined, the
ACHP and the SHPO draft and executive an MOA acknowledging satis-
factory mitigation of adverse effects.
47
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Project Background EPA's environmental review of GMA's application at that time
determined the proposed project did represent a potential signi-
ficant adverse effect because induced development could occur as
a result of the new facilities in a manner which might alter the
historic and scenic values associated with the National Park.
EPA prepared and submitted a "Preliminary Case Report" to the
Advisory Council which served as a basis for consultation among
several involved agencies, including EPA, the ACHP, PA-DER, the
Pennsylvania SHPO, the NPS, and local officials. The efforts
resulted in a Draft Memorandum of Agreement in 197 8 which was
supported by several of the parties. However, the efforts
faltered when a more comprehensive version of the MOA could not
gain the necessary support.
EPA recognized the impasse in executing an MOA and in consulta-
tion with the involved parties agreed that an Environmental
Impact Statement specified under the National Environmental
Policy Act (NEPA) was needed to more thoroughly study the issue.
This EIS combines the requirements of NEPA and NHPA to yield a
single process which meets all applicable regulations. Thus, one
of the primary goals of the EIS has been to develop solutions to
the wastewater problems in the area that would minimize impacts
on cultural resources and develop mitigative measures to control
secondary impacts resulting from induced growth. The EIS estab-
lished an information base upon which the local jurisdictions and
other authorities have deliberated the relative merits of waste-
water management alternatives. The EIS process has also
established a number of forums that expedited negotiations for
the MOA over the course, of two years. These have included
regular meetings of the Public Advisory Group and the Interagency
Coordinating Group, newsletters, public meetings, public hearings
and most recently intensive dialogues have taken place between
EPA, NPS, ACHP, the local jurisdictions and their consultants.
The findings of these forums are that the proposed action does
have the potential for adverse effect on the Gettysburg Battle-
field Historic Distric. These adverse effects include the his-
toric and prehistoric archaeologic resources that may be dis-
turbed with the construction of sewer interceptors and collectors
pump stations, and wastewater treatment plants. Adverse impacts
include both direct construction impacts as well as potential
aesthetic impacts associated with the form, height, and color of
facilities in relation to the surrounding landscape. The other
impact defined is the amount, rate, and distribution of resi-
dential growth that would occur with the recommended action.
This induced growth could have the effect of adversely impacting
the historic setting of the Battlefield District through the
development of residential and commercial structures which are incon-
sistent with existing development and the surrounding landscape.
Mitigative Measures In order to mitigate these adverse effects, the key parties have
agreed to stipulations in the MOA which when executed will satis-
factorily implement measures to protect identified resources.
This includes an archaeologic survey of proposed sewer intercep-
tor rights of ways, pump station sites, and wastewater treatment
plant locations. A determination of eligibility of resources
located during this survey will be obtained for inclusion in the
Natonal Register. The final proposed wastewater facility
improvements are also to be designed to minimize visual and
construction impacts on the surrounding landscape.
EPA has also agreed to ensure that the local municipalities adopt
an Historic District Ordinance under the Pennsylvania Historic
48
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District Act (P.L. 282, No. 167). This Act permits Pennsylvania
municipalities to delineate and officially map historic
districts based upon a survey of historic and archaeological
resources worthy of preservation. Once an ordinance has been
drafted, the Pennsylvania Historic and Museum Commission will
certify the historic significance of the district delineated.
This Ordinance will establish an Historical and Architectural
Review Board and promulgate design guidelines for review of the
erection, alteration, restoration, demolition or razing of
buildings in that district. These activities cannot take place
unless a certificate of appropriateness has been issued
attesting to the compatibility of the action with the provisions
of the ordinance.
Lastly, the National Park Service will work with local
organizations to establish a scenic easement program. This
program will inform property owners in potentially impacted
areas of the tax advantages of granting scenic easements or full
property interest to non-profit organizations. In addition, the
NPS will work to develop model landscape plans which can be
voluntarily used by developers and owners of existing real
estate to screen buildings and structures from Park viewpoints.
Following is the list of mitigative measures developed through
the NHPA and EIS consultation process which EPA proposes be
included into the Memorandum of Agreement. The proposal has
been informally agreed to by all involved parties and will be
formally transmitted with concurrence of EPA, NPS, and the SHPO
to the SCHP for ratification.
PROPOSAL FOR INCLUSION IN THE MEMORANDUM OF AGREEMENT
Stipulations
I. EPA will ensure that any grant funds awarded by EPA for
wastewater treatment facilities will be granted only upon the
following conditions, and in the event of such award EPA will
ensure that these measures are carried out.
A. Primary Impacts
1. Archeology
a. Prior to the award of an EPA Step II grant, all readily
available information on the location, type, and significance of
known prehistoric and historic archeological properties in the
vicinity of the proposed project construction areas will be
assembled and made available for facilities planning and design
use.
b. As soon as possible after the award of an EPA Step II grant
and using the results of previous identification efforts
referred to in Stipulation A(l)(a), archeological surveys of
proposed sewer interceptor rights-of-way, pump station sites,
and wastewater treatment plant locations will be conducted.
These surveys will be undertaken in consultation with the
Pennsylvania SHPO and in accordance with 36 CFR Part 66,
Appendix B, "Guidelines for the Location and Identification of
Historic Properties Containing Scientific, Prehistoric,
Historical, or Archeological Data."
49
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c. In the event that significant archeological properties are
found that may meet the National Register Criteria (36 CFR Part
60), a determination of eligibility for inclusion in the
National Register will be obtained from the Secretary of the
Interior.
d. During the preparation of the plans and specifications of
the proposed wastewater treatment system, significant
archeological properties will be avoided to the maximum extent
feasible. If avoidance is not feasible, a data recovery plan
covering affected archeological properties throughout the
project area will be developed consistent with the Council's
Handbook, Treatment of Archeological Properties. The plan will
include consideration of important research questions related to
the prehistory and history of the Adams County area. The plan
will be submitted to the Pennsylvania SHPO and the Council for
review.
If neither the SHPO nor the Council objects within 30 days after
receipt of the plan, the plan will be implemented. If either
the SHPO nor the Council objects, the parties will meet in order
to resolve the objections.
e. All requests for proposals, scopes of work, and draft
reports for archeological and related research will be submitted
to the Pennsylvania SHPO for review and approval.
f. The archeological work called for in Stipulations A(l)(b),
A(1)(c), and A(1)(d) will be conducted under the direct
supervision of an archeologist (s) who meets, at a minimum, the
qualifications set forth in 36 CFR Part 66, Appendix C.
2. Wastewater Facilities Design
The design of all above-ground portions of the proposed
wastewater facility improvements will be accomplished in an
appropriate manner to minimize the visual and construction
impacts on surrounding National Register Historic Districts.
The designs must be reviewed and approved by the Pennsylvania
SHPO.
B. Secondary Impacts
1. Historic District Ordinance
a. Prior to the award of an EPA Step II grant, EPA will require
that a copy of a Resolution to Adopt an Historic District
Ordinance passed by each municipality which will be provided
sewerage service under the proposed facilities be submitted.
b. Prior to the award of an EPA Step II grant, EPA will require
to be submitted evidence that the municipalities have drawn
proposed boundaries for an historic district which have been
approved in writing by the Pennsylvania SHPO, and conducted a
thorough inventory of historic buildings, structures, sites or
areas which could be affected by development resulting from the
proposed waste water treatment facilities.
c. Prior to the award of an EPA Step III grant, or prior to epa
approval of local contracts for construction of wastewater
treatment facilities, EPA will require to be submitted a copy of
an historic district ordinance, passed in accordance with
Pennsylvania Act 167 (53 P.S.
50
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si 0002) by the local governing body of each municipality served
by the proposed facilities, and certified by the Pennsylvania
Historical and Museum Commission. The ordinance will designate
certain areas as an historic district based upon the information
obtained in the prior surveys.
d. Prior to the award of an EPA Step III grant, or prior to EPA
approval of local contracts for construction of wastewater
treatment facilities, EPA will require that it be shown that a
Board of Historical Architectural Review has been appointed for
each historical district consisting of a registered architect,
licensed realtor, a building inspector and two or more citizens
who have some knowledge and interest in historic presevation.
(53 P.S. § 8003) .
e. Prior to the award of an EPA Step III grant, or prior to EPA
approval of local contracts for construction of wastewater
treatment facilities, EPA will require to be submitted a copy of
the specific guidelines for architectural review which each
board will use in making recommendations regarding plans for the
erection, reconstruction, alteration, restoration, demolition or
razing of buildings in their district, along with documentation
showing that these guidelines were drafted by a suitably
qualified professional who was approved by the Pennsylvania
Historical and Museum Commission. EPA will further require that
it be shown that these guidelines have been submitted to the
Pennsylvania Historical and Museum Commission, the National Park
Service and the Council for their comments.
II. National Park Service Measures.
A. Scenic Easements
The National Park Service will work through local organizations
to inform property owners in potentially impacted areas of the
income tax, estate tax, and property tax advantages of granting
senic easements or full property interests to non-profit
entities such as Historic Gettysburg-Adams County or the Park
Service itself. The voluntary nature of this type of program
will be stressed.
B. Model Landscape Plans
The Park Service will also undertake the development of model
landscape plans that could be used by developers to screen new
construction from Park Service holdings. These models will
present different options on the use of indigenous plant
materials and show how these materials may enhance and increaste
the value of properties in a development. These model plans
would be made available to local developers, municipal planning
boards conducting subdivision review, and the Adams County
Planning Commission. Completion of these two projects should be
accomplished within six months after the execution of this
Agreement.
^ (date)
Environmental Protection Agency
(date)
Pennsylvania State Historic Preservation Officer
(date)
National Park Service
51
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MAILING LIST
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GETTYSBURG EIS MAILING LIST
Federal Agencies
Advisory Council on Historic
Preservation
Council on Environmental Quality
Federal Emergency Management Agency
National Agricultural Lands Study
US Army Corps of Engineers
US Bureau of Persons
US Department of Agriculture
Cooperative Extension Service
Soil Conservation Service
US Department of Commerce
Office of Environmental Affairs
US Department of Defense
US Department of Energy
Office of the Secretary for the Environment
US Department of Health, Education and Welfare
US Department of Housing and Urban Development
US Department of the Interior
Bureau of Outdoor Recreation
Fish and Wildlife Service
National Water Resource Analysis Group/
Eastern Land Use Team
National Park Service
Heritage, Conservation and
Recreation Service
US Department of Transportation
Federal Highway Administration
Marine Environmental Protection Division
US Department of Treasury
US General Services Administration
Water Resources Council
Pennsylvania State Agencies
Department of Agriculture
Department of Commerce
Department of Community Affairs
Department of Environmental Resources
Bureau of Air Quality and Noise Control
Bureau of Community Environmental Control
Bureau of Radiological Health
Bureau of Solid Waste Management
Bureau of State Forestry
Pennsylvania State Agencies (Cont.)
Bureau of State Forestry
Bureau of State Parks
Bureau of Topographic and Geological
Survey
Bureau of Water Quality Management
Division of Coordination
Division of Solid Waste Management
Division of Water Supply & Sewerage
Regional Sanitary Engineer
State Conservation Commission
Department of Health
Department of Transportation
Environmental Hearing Board
Fish Commission
Game Commission
Governor's Office of the Budget
Historical and Museum Commission
Interstate Commission on the Potomac
River Basin
State Clearinghouse
Citizens Groups
Air Pollution Control Association
America the Beautiful Fund, Washington, DC
Audobon Naturalist Society of the Central
Atlantic States, Inc., Washington, DC
Citizens' Advisory Council to PA Dept. of
Environmental Resources
Citizens Environmental Task Force
Environmental Defense Fund
Group Against Smog and Pollution
Lake Heritage Property Owners
League of Women Voters, Gettysburg, PA
Leaque of Women Voters, Philadelphia, PA
National Audubon society, Harrisburg, PA
National Parks and Conservation Association,
Washington, DC
Natural Resources Defense Council,
Washington, DC
PA Forestry Association, Mechanicsburg, PA
PA Horticultural Society, Philadelphia, PA
PA Lung Association, Hershey, PA
PA Roadside Council, Inc., Philadelphia, PA
PA State Fish and Game Protective Association
Philadelphia, PA
Rachel Carson Trust for the Living Environment,
Inc., Washington, DC
53
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Citizens Groups (Cont.)
Elected Officials (Cont.)
Sierra Club, PA Chapter
Sierra Club, Southwestern Group,
Pittsburg, PA
Water Pollution Control Association,
Washington, DC
Wilderness Society
Wildlife Society
Local Agencies
Cumberland Township
Chairman
Engineer
Planning Commission
Solicitor
Cumberland Township Authority
Gettysburg Borough
Council
Engineer
Planning Commission
Solicitor
Gettysburg Municipal Authority
Lake Heritage Municipal Authority
Mt. Joy Township
Chairman
Planning Commission
Solicitor
Mt. Pleasant Township
Chairman
Engineer
Straban Township
Engineer
Planning Commission
Solicitor
Supervisors
Elected Officials
Honorable Richard Thornburg
Governor of Pennsylvania
Honorable H. John Heinz, III
United States Senator
Honorable Richard S. Schweiker
United States Senator
Honorable William F. Goodling
United States Representative
Mr. & Mrs. Chris H. Walters
(Congressman Goodling1s Staff)
Honorable William J. Moore
Senate of Pennsylvania
Honorable Ralph W. Hess
Senate of Pennsylvania
Honorable John D. Happer
Senate of Pennyslvania
Honorable Kenneth J. Cole
Pennsylvania House of Representatives
Honorable A. Corville Foster, Jr.
Pennsylvania House of Representatives
Honorable Eugene A. Geesey
Pennsylvania House of Representatives
Honorable Fred C. Noye
Pennslyvania House of Representatives
Public Advisory Group
Jack A. Corbin
John Earnst - Superintendent, National
Park Service
Ruth Gritsch - League of Women Voters
Ronald Hankey - President, Gettysburg Area
Chamber of Commerce
Crosby L. Hartzell, Jr. - President, Retail
Merchants Association
Charles H. Huber, Jr. - Taxpayers Association
Walter Lane
George N. Mahaffey
George W. Olinger - Landlords Association
Charles A. Strayer - Straban Township
Builders Association
Rev. James W. Tipton - Historic Gettysburg
Adams County
John B. Zinn, Jr.
Media
Newspapers
Five Star News, Manchester, PA
Gettysburg Times, Gettysburg, PA
Hanover Sun, Hanover, PA
Patroit News, York, PA
Sunday News, York, PA
York Daily Record, York, PA
York Dispatch, York PA
York News Agency, York, PA
Radio
WGCB, Red Lion, PA
WGET, Gettysburg, PA
WHVR-AM, Hanover, PA
WNOW AM-FM, York, PA
WSBA, York, PA
WZIX, York, PA
TV
Cypress Cable TV, Reedville, PA
TV Host Inc., Harrisburg, PA
WHP-TV, Harrisburg, PA
WITF-TV, Hershey, PA
WLYH-TV, Lebanon, PA
WSBA-TV, York, PA
WTPA-TV, Harrisburg, PA
54
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Citizens
Citizens (Cont.)
Mr. Francis B. Alberto
Mr. and Mrs. Marvin L. Anderson
Ms. Jane Boblitz
Ms. June Boherg
Mr. Jack Carhon
Mr. and Mrs. Richard Chatelain
Mr. David Clark
Ms. Gloria Clark
Mr. H. Wayne Cluck
Mr. and Mrs. David Cobb
Mr. Joseph L. Cole
Mr. Phillip Cole
Mr. Irvin S. Conover
Mr. Bruce C. Cooper
Elwyne C. cooper
Mr. William E. Craumer
N. M. Cullison
Ms. Louise F. Daves
Mr. Walton V. Davis
Ms. Ruth M. Detwiler
Mr. Mark A. Eckert
Mr. Frank Ferguson
Mr. Harry Frankhouser, Jr.
Mr. Edwin Frownfelter
Mr. Joseph Galant
Ms. Kathleen A. George
Mr. and Mrs. Bob Greer
Mr. Paul Grumbine
Ms. Susan Gruver
Mr. Donald C. Gulden
Ms. Bonnie J. Hammmond
Mr. J. G. Haney
Mr. Milburn J. Harris
Mr. and Mrs. Clarence H. Hauson
Mr. William F. Hill
Ms. Eileen S. Holmes
A. B. Inskip
Mr. Jordan
Ms. Diana S. Kasu
Mr. Jack F. Klein
Ms. Barbara A. Klindt
Mr. Victor Krea
Mr. John K. Latt
Mr. Robert T. Lawn
Mr. Leroy Lesan
Mr. Eugene S. Long
Mr. Harvey F. Ludwig
Mr. Harvey O. Lytle
Mr. Charles Marass
Mr. Edgar May
Mr. Hugh c. McAllheny
Mr. Ed Merrell
Mr. and Mrs. Gerald Miller
Mr. Roger C. Mitterling
Mr. Steve J. Monforte
F. J. Montgomery
Mr. Phillip 0. Neth
Mr. Lonny Nummet
Mr. Joseph J. Pellegrini
Mr. Thomas Phillip, Jr.
Mr. A. F. Premo, Jr.
Mr. Richard C. Price
Mr. Raymond C. Protzman
Mr. Clay Rebert
Ms. Sonja Y. Reisinaer
Mr. and Mrs. M. J. Rockey
Mr. and Mrs. C. K. Roulette & Family
Ms. Paula Rubuer
Mr. Michael Rura
Mr. John K. Salt
Mr. Byril Sanders
Mr. Michael E. Sanders
Mr. Frank Sheak
Mr. Dean A. Shultz
Mr. Edward Slening
Mr. Edward Smith
Mr. Randy Smi th
Mr. J. C. Sneeringer
Ms. Sharon Sontheimer
Ms. Susan Stan
Ms. Pearl Steinour
Mr. John A. Stemen
Mrs. Strnad
Mr. Carl T. Swinn
Ms. Peggy Taughenbaugh
Mr. Roy E. Thomas
Mrs. Dorothy Thompson
Ms. Ethel W. Thorniley
Mr. Dave Walters
Mr. John D. Warner
Mr. Allen Weikert
Mr. Leo Weiner
Mr. Steve Wennberg
Mr. Glenn Whaley
Mr. and Mrs. Roger D. Williamson
Mr. Clifford Yarwood
Mr. Lee A. Yohn
Mr. Gary L. Yount
Others
Adams County Home Builders Association
Adams County Library
American Water Works Company, Inc.
Carroll Valley Sewer and Water Authority
Century 21 Real Estate
Environmental consultant and Testing
Services, Inc.
Gannett, Fleming, Corddry & Carpenter
International Research Evaluation
55
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REFERENCES
-------
Adams County Planning Commission. 1968. Comprehensive County
Plan for Water and Sewage Systems, Adams County. In con-
junction with Clifton E. Rodgers and Associates, Harrisburg,
PA. 147p.
Adams County Planning Commission. 1970. Adams County Comprehen-
sive County Plan. In conjunction with Clifton E. Rodgers
and Associates, Harrisburg, PA. Three technical reports and
a summary report: Part 1, Background Information; Part 2,
Planning Proposals; part 3, Implementation Program; Summary
Report, variously paged.
Adams County Planning Commission. No date. Adams County Land
Subdivision Regulations. Gettysburg, PA. 32p.
Adams County Planning Commission. No date. Adams County Pro-
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Adams County Planning Commission. No date. Housing Study: An
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Commonwealth of Pennsylvania. US Government Printing
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Air Quality Report. 1978. Commonwealth of Pennsylvania:
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Quality and Noise Control. Harrisburg, PA.
Beranek, L. L. 1971. Noise and Vibration Control. McGraw-Hill,
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Black, Terry. (oral communication). June 22, 1979. Conversa-
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York, Pennsylvania and David L. Bush, Air Quality Scientist,
WAPORA, Inc., NY, NY.
Borough of Gettysburg. 1977. The Gettysburg Borough Zoning
Ordinance (Ordinance 902-75, October 13, 1975, Article 1,
Section 100; Revised January 11, 1977). Gettysburg, PA.
252p.
Buchart-Horn, Inc. 1978. Cumberland Township Authority 201
Facilities Plan, Report on Program Requirements Memorandum
78-9, US Route 140 Area. York, PA. Variously paged.
Burchell, Robert W. and David Listokin. 1978. The Fiscal Impact
Handbook. Center for Urban Polisy Research, New Brunswick,
NJ. 48Op.
Clean Air Act Amendments. 1977. Public Law 95-95. 95th
Congress. August 7, 1977.
Climate of Gettysburg, Pennsylvania. June, 1977. National
Oceanic and Atmospheric Administration. Environmental
Data Service. National Climatic Center. Asheville, NC.
57
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Commonwealth of Pennsylvania - Title 25. 1971-1972. Rules and
Regulations. Part I. Department of Environmental Re-
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Article III - Air Resources. Chapter 131 - Ambient Air
Quality Standards.
Cumberland Township Board of Supervisors. 1973. The Cumberland
Township Subdivision and Land Development Ordinance
(No. 28), Cumberland Township, PA. 47p. (includes Proposed
Revisions of June 7, 1979)
EPA. 1974. Population Distribution of the United States As a
Function of Outdoor Noise Level. 550la-74-009. Washington,
DC.
Federal Register. 1971-79. National Ambient Air Quality
Standards.
Federal Register. September 12, 1978. States Attainment Status.
Gannet Fleming Corddry and Carpenter, Inc. 1976. Wastewater
Management Facilities Plan (201) 197b: Volumes 1 and 2.
Prepared for the Gettysburg Municipal Authority, Harrisburg,
PA. Vol.1, 125p; Vol. 2, 250p.
Gettysburg Area School District (GASD). 1973. A Long Range
Development Plan (revised). Gettysburg, PA.
Gettysburg Area School District. 1978. Table of Grade Enroll-
ments 1965-1966 Through 1977-1978, and Projected Enrollments
1977-1978 Through 1987-1988. Gettysburg, PA.
Gettysburg Area School District. 1979a. Budget Document 1979-
1980. Gettysburg, PA. 42p.
Gettysburg Area School District. 1979b. Long Term Development
Plan. Gettysburg, PA.
Gettysburg-Cumberland Demonstration Program: Technical Report
#2, Ecological Studies. (In Conjunction with Wallace,
McHarg, Roberts and Todd, and Gladstone Associates;
Philadelphia, PA) Harrrisburg, PA. 60p.
Gettysburg Municipal Authority. 1977. Water Supply System
Improvement Study. Harrisburg, PA. 80p.
Gettysburg Municipal Authority. 1978b. Report on Operation of
Water System for the Period October 1, 1977 to September 30,
1978. Gettysburg, PA. 17p.
Health Resources Planning and Development, Inc. 1979. Acute
Inpatient Care (Draft) Section of the Health System Plan.
Camp Hill, PA. 312-414pp.
Holzworth, George C. January, 1972. Mixing Heights, Wind Speeds
and Potential for Urban Air Pollution Throughout the Con-
tiguous United States. EPA Publication AP-101. Research
Triangle Park, NC.
Hughey, Ronald E. 1973. Aquatic Biology Investigation of the
Gettysburg Sewage Treatment Plant on Rock Creek, Adams
County. Pennsylvania Department of Environmental Resources,
Stream File 5.11.2, 7p.
58
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Hughey, Ronald E. 1978. Aquatic biological investigations of
Rock Creek, Adams County. Pennsylvania Department of Envi-
ronmental Resources, Stream File 5.11.2, 3p.
Lake Heritage Property Owner's Association, Inc. 1973. Revised
Bylaws, Code of Regulations. Gettysburg, PA. 8p.
Littlestown Area School District (LASD). 1978a. Proposed budget
1978-1979. Littlestown, PA. 17p.
Littlestown Area School District. 1978b. Long range development
plan. Section 8: School facilities (3p.), Section 4: Pupil
enrollment projections (2p.) Littlestown, PA.
Mount Joy Board of Supervisors. 1979. Mount Joy Township sub-
division and land development ordinance. Mount Joy, PA.
74p.
Mount Pleasant Township Board of Supervisors. 1972. The Mount
Pleasant Township subdivision and land development regula-
tion. Mount Pleasant, PA. 39p.
Pennsylvania Department of Agriculture, Crop Reporting Service.
1972. Pennsylvania Orchard and Vineyard Survey. Harris-
burg, PA. 38p.
Pennsylvania Department of Agriculture, Crop Reporting Service.
1977. 1976 Crop and Livestock Annual Summary, CRS-67.
Harrisburg, PA.
Pennsylvania Department of Commerce, Bureau of Employment
Security. 1979. Labor Market Analyst, Annual Planning
Report: York Labor Market Area, Pennsylvania. York, PA.
52p.
Pennsylvania Department of Commerce, Bureau of Statistics. Re-
search and Planning. 1978. Pennsylvania County Industry
Report: Adams County. Harrisburg, PA. 27p.
Pennsylvania Department of Commerce. No Date. Adams County
Industrial Report (Release No. M-5-70). Harrisburg, PA.
25p.
Pennsylvania Department of Community Affairs (DCA). 1970 Through
1977. Local Government Financial Statistics: Adams County.
Harrisburg, PA. Variously paged.
Pennsylvania Department of Community Affairs. 1972a. Gettys-
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Economic Studies. (In Conjunction with Wallace, McHarg,
Roberts, and Todd, and Gladstone Associates; Philadelphia,
PA) Harrisburg, PA. 70p.
Pennsylvania Department of Community Affairs. 1972b. Gettys-
burg-Cumberland Demonstration Program (In Conjunction with
Wallace, McHarg, Roberts, and Todd, and Gladstone Asso-
ciates; Philadelphia, PA). Harrisburg, PA. 155p.
Pennsylvania Department of Community Affairs. 1975. A Study
of the Economic Impact of the Gettysburg National Military
Park and Tourism on the Gettysburg Area. Harrisburg, PA.
155p.
59
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Pennsylvania Department of Community Affairs. 1979a. Annual
Budget of the Township of Cumberland for the Year 1979.
Harrisburg, PA. 7p.
Pennsylvania Department of Community Affairs. 1979b. Draft
Gettysburg Borough Comprehensive Plan (unadopted). Harris-
burg, PA. (Unpaginated).
Pennsylvania Department Community Affairs. 1979c. Annual Budget
Report and Guide for Mount Pleasant Township for the Year
1979. Harrisburg, PA. 26p.
Pennsylvania Department of Community Affairs. 1979d. Annual
Budget for Adams County, PA for the Year 1979. Harrisburg,
PA. 57p.
Pennsylvania Department of Community Affairs. 1979e. Cumberland
Township Comprehensive Plan. Harrisburg, PA. Variously
paged.
Pennsylvania Department of Education. 1971 Through 1979. Audi-
tor's Reports (DECO-502) and Annual Financial Reports
(DECO-500) for Gettysburg Area School District, and Littles-
town Area School District. Harrisburg, PA. Variously
paged.
Pennsylvania Department of Education. 1979a. A Listing of
Pennsylvania Non-public Schools Having Elementary Enroll-
ments 1978-1979. Harrisburg, PA. 172p.
Pennsylvania Department of Education. . 1979b. A Listing of
Pennsylvania Non-public Schools Having Secondary Enrollments
1978-1979. Harrisburg, PA.
Pennsylvania Department of Education. 1979C. Perpetual School
Building Inventory Listing as of September 15, 1978.
[Public] School Buildings in Operation 1978-1979. Harris-
burg, PA. 287p.
Pennsylvania Department of Labor and Industry. 1970. Through
1979. York Labor Market Letter. Bureau of Employment
Security, York, PA. Variously paged.
Pennsylvania Department of Labor and Industry. 1976. Pennsyl-
vania Occupational Projections. Bureau of Employment
Security, Labor Market Information Section, Research and
Statistics Division. Harrisburg, PA. 586p.
Pennsylvania Department of Labor and Industry. 1979. Annual
Planning Report, Fiscal Year 1980. Bureau of Employment
Security, Labor Market Analyst for York, Pennsylvania.
Harrisburg, PA. 50p.
Pennsylvania Department of Transportation. 1977. Pennsylvania
Traffic Data Annual Report: 1977 (and 1975 Traffic Volume
Map of Adams County). Bureau of Transportation Planning
Statistics. Harrisburg, PA. 40p.
Pennsylvania Office of State Planning and Development. 1974a.
Net Migration by Age, Sex, and Race in Selected Counties
1960-1970. Harrisburg, PA.
Pennsylvania Office of State Planning and Development. 1974b.
Patterns of Commutation in Pennsylvania by County. Harris-
burg, PA. 78p.
60
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Pennsylvania Office of State Planning and Development. 1978.
Pennsulvania Projection Series Summary Report (No. 78
PPS-l), State Economic and Social Research Data Center.
Harrisburg, PA. Unpaginated.
Regional Science Research Institute. 1976. Housing Requirements
and Needs in Pennsylvania: 1970-1990. (A Report to the
PA-DCA). Philadelphia, PA. 151p.
State Industrial Directories, Inc. 1972. Pennsylvania State
Industrial Directory. New York, NY. pp.G-13 Through
G-16.
Straban Township Board of Supervisors. 1964. Land Subdivision
Regulations. Straban, PA.
Straban Township Board of Supervisors. 1974. Buidlign Permit
Ordinance. Straban, PA.
Straban Township Board of Supervisors. 1978. Annual [Budget]
Report to the Treasurer. Straban, PA.
Straban Township Board of Supervisors. No Date. Development
Potential - 1981 (Map). Straban, PA.
US Department of Commerce, Bureau of the Census (DOC). 1971.
1970 Census of Population, General Population Characteris-
tics: Pennsylvania (PC (1) - B40). US Government Printing
Office, Washington, DC. 287p.
US Department of Commerce, Bureau of the Census. 1972. 1970
Census of Population, Detailed Characteristics: Pennsyl-
vania (PC(1) - D40). US Government Printing Office,
Wa shi ngton, DC.
US Department of Commerce, Bureau of the Census. 1973. 1970
Census of Population and Housing. York, PA, SMSA Census
Tracts. US Government Printing Office, Washington, DC.
US Department of Commerce, Bureau of the Census. 1977. Projec-
tions of the Population of the United States, 1977 to 2050.
Series P-25, No. 704. US Government Printing Office,
Washington, DC. 87p.
US Department of Commerce, Bureau of the Census. 1978. Illus-
trative projections of State Populations: 1975 to 2000
(Advance Report). Series P-25, No. 735. US Government
Printing Office, Washington, DC. 4p.
US Department of Commerce, Bureau of the Census. 1979a. Projec-
tions of the Number of Households and Families: 1979 to
1995. Series P-25, No. 805. US Government Printing Office,
Washington, DC. 22p.
US Department of Commerce, Bureau of the Census. 1979b. 1976
Population Estimates and 1975 and Revised 1974 Per Capita
Income Estimates for Counties, Incorporated Places, and
Selected Minor Civil Divisions in Pennsylvania. Series
P-25, No. 777. US Government Printing Office, Washington,
DC. 42p.
US Department of Interior, National Park Service. 1979. Draft
General Management Plan (for) Gettysburg National Military
Park, Pennsylvania. 126p.
61
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US Department of the Interior, National Park Service. Undated.
Revised Draft General Management Plan for the Gettysburg
National Military Park, Pennsylvania. 141p.
US Department of the Interior, National Park Service, Undated.
Draft general management plan and draft environmental
assessment for the Gettysburg National Cemetary.
Pennsylvania. 117p.
US Water Resources Council. 1972. OBERS Projections, Regional
Economic Activity in the United States. Series E.
Washington, DC.
Van Orden, Dean. (oral communication). June 22, 1979. Conver-
sation Between Dean Van Orden, Air Quality Engineer,
PennDER, Harrisburg, Pennsylvania and David L. Bush, Air
Quality Scientist, WAPORA, Inc., NY, NY.
WAPORA, Inc. 1979. Chlorine Toxicity Survey Data. Report Sub-
mitted to USEPA Region II.
62
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APPENDICES
-------
APPENDIX A
Draft EIS Included by Reference
-------
APPENDIX B
Comment Letters
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3&oard of Supervisors
Straban X3owas!)ip, 3A&ants (Touitt:?, ~pa.
Townthip erected tJJfi
STEWART E. DAVIS
FREDERICK M. SHEALER
EMERY E. SIBERT
ARTHUR WEANER. Sec. - Treas.
R. D. 6, BOX 320 (We*ner Rd.)
GETTYSBURG. PA. 17325
PHONE 717 334 - 6140
January 16, L981
Nr. Thomas Slenkamp
Project Monitor, Region 3
6th and Walnut Streets
Philadelphia, Pa. 19106
Dear Mr. Slenkamp:
Straban Township Officials outlined in their letter dated, May 2, 1981, and
at the September meeting with WAPORA, Inc. several discrepancies in the EIS Study.
In reviewing the December, 1980 Draft Environmental Impact Statement for
Gettysburg, Pa. Area Wastewater Treatment Facilities, the majority of these statements
and items are still included as follows:
(l) Segment 3 indicated that the area along both sides of Business Rt. 15
is now serviced by sewer. None of the existing EDU's along Business
Rt. 15 are serviced by Public Sewer. The sewer only services the
development of Twin Oaks and The Lutheran Home, which lie East of
Business Rt. 15.
(2) The Study still indicates that Segment 18 is the area where the most
development will occur by 2005. Straban Township disagrees with this.
It is evident that there is a need for Public Sewer to service the
existing EDU's in this area because of malfunctions, but the low density
of development makes it uneconmical to construct sewer lines to service
this small number of EDU's. The majority of the land in Segment 18 is
presently used as productive farm land. There has been no proposals
for developing this land presented to the Supervisors, with the exception
of several lots fronting along the roads. The Township feels that
B-l
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this area may eventually be developed, but the projection of 320 EDU's
as indicated in the Study is too great. It would be desirable to
service as many of the existing EDU's along Business Rt. 15 as economically
feasible at this time and size the collection line large enough for
future development. This area should not be considered as the most
prominent area in the Township for future development.
(3)
On Page 47, Segment 4 (U.S. RT. 30) is not mentioned under Future Land
Use--Straban Township. This segment should be recognized.
(4) The Study indicates that Segment 4, by 2005, will have a population
growth of 42 EDU's or 9,300 gallons will be reserved in the treatment
system for future growth for this area. The development potential of
this area is far greater than this estimate. It is questionable of how
this projection was arrived at. This area now has current development
under construction, which will require more than 42 EDU's. A permit for
a Sewage Treatment Plant, to service this development and existing EDU's
along U.S. RT. 30, has been issued to Straban Township by the Penna. Dept.
of Environmental Resources. This permit was issued under the stipulation
that the treatment plant must be abandoned and the area serviced by the
Regional Sewer, when it becomes available.
(5) The Study is unclear as to what capacity will be reserved for Straban
Township at the treatment plant. Is it the Design Flows shown in Table IV-8?
cc: DER, Corriveau, PE, Hbg.
Schultz, ESQ.
STPC, Redding, Sec.
STA, Hull, Sec.
Davis, ESQ.
GMA, Larson, Chn.
GEC, Shultz
CRC, Jordan
Mr. Strayer
Mr. Zinn,P.A.G.
Miller, ACPC
Sincerely your,s,
STRABAN TOWNSHIP SUPERVISORS
Arthur Weaner/Secretary/Treasurer
B-2
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W HOWARDCORD0RV
JOHN R DIET?
H BRUCE GERBER
MAURICE A WAOSWORTM
WALTER K • MORRIS
J DOUGLASS BERRY
HAROLD T HADDINGTON
JOHN E WATERS
CHARLES H KRESSLER
Gannett Fleming Corddry and Carpenter, Inc.
ENGINEERS AND PLANNERS
RA Y F STAUFF ER
F JAMES KNIGHT
C KENNETH MYERS
GEORGE H SMITH
ROBERT j OtETI
RONALD J [jRNEViCh
Russell s ki ingensmiti
EDWARD W MONROE
DAVID ANTEMuCCi
PAUL W BRICKER
William k Corliss jr
ROBERT A STARK
JOHM J YURiCK
THOMAS R 8ENYO
william c EhRESman
FREDERICK FUTCHKO
JAMES G HANEY
GERALD P VOEGlER
GERALD B SPECK
ROGER J BANKS
GEOFFREY A FOSBROOK
Thomas m raChford
STEPHEN F TALIAN
MARLIN K UlSH
JAMES R MADARA
CHARLES W PICKERING
WILLIAM H ALLEN
MARCELLO H SOTO
FRANK J D0NATELL1
HERMAN R STARTZENBACH
PAUL E PAUL
P O BOX 1 963
HARRISBURG. PENNSYLVANIA 17105
PHONE 7 I 7 763-72 I I
IOSEPM W LIPSCOMB
JAMES L LONG
ANTON f MIORIN
CABLE ADDRESS: GANFLEC
TELEX 84-2375
January 23, 1981
Mr. Thomas Slenkamp
Environmental Protection Agency (3IR61)
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Slenkamp:
On behalf of the Gettysburg Municipal Authority, we have reviewed
the Draft EIS on wastewater management facilities for the Gettysburg
area. We feel that, with consideration and cooperation among all en-
tities involved in the project, the five alternatives formulated in the
EIS can lead to the development of a wastewater management plan that will
substantially benefit the inhabitants of the planning area.
The existing Gettysburg wastewater treatment plant would be upgraded
and expanded, in varying degrees, under any one of the alternatives. There-
fore, there is relatively little difference among the costs or other effects
of the varous alternatives on the residents of Gettysburg. However, there
are some comments we would make which pertain to all of the proposed alter-
natives .
First, the year 2005 design flows from the existing Gettysburg service
area (Segments 1 and 3) were developed by allowing 80 gallons per person
per day and adding the estimated I/I of 0.5 million gallons per day. For
all but Alternative A, this amounts to a design flow from Segments 1 and 3
consisting of 0.755 mgd sewage and 0.5 mgd I/I, for a total of 1.255 mgd.
We request that EPA consider increasing Gettysburg's portion of the total
design flow to at least 1.6 mgd for the following reasons:
Re: Draft Environmental Impact Statement
Gettysburg Area Wastewater Treatment
Facilities
B-3
Continuous eSttttlet <£inct <99
-------
Gannett Fleming Corddry and Carpenter, inc.
Mr. Thomas Slenkamp
Philadelphia, Pennsylvania -2- January 23, 1981
1. The metered water consumption in Gettysburg during the past
two years has averaged 1.0 mgd, excluding fire protection,
leaks, etc. Assuming that an average of 85 percent of this
is returned to the sewer system, the present average sewage
flow is about 0.85 mgd.
2. The 0.5 mgd I/I allowance, which was estimated in GFCC's
preliminary I/I analysis, may be too low as a result of
recent draft guidelines issued by EPA on I/I analyses. The
implications of the draft guidelines are the design I/I
allowance should be increased from 0.5 mgd to 0.7 mgd.
The sum of these revised components totals 1.55 mgd, and does not account
for any future growth or any increase in I/I over the next 25 years. Should
EPA's projected growth (1.6% total growth in Gettysburg) over the next 25
years be too low, or should the I/I component increase, the flow from
Gettysburg in the year 2005 may exceed 1.6 mgd.
Our second concern, which has been expressed previously, is over the
physical condition of the existing Gettysburg treatment plant. Please re-
fer to our letter of August 4, 1980 for details. We are not in agreement
with the EIS's conclusion that the plant is suitable for future use with
relatively minor improvements. By the year 2005, this facility will have
been in operation for over 50 years with only minor improvements. In order
to prevent the people of Gettysburg from being saddled with an 0 5 M bur-
den long before the design year, we request that a detailed evaluation of
the plant's suitability for future use be conducted prior to EPA's final
recommendation.
We also question the feasibility of an upgraded and expanded facility
on the existing plant site, particularly with the denitrification and de-
chlorination facilities proposed by EPA. We would appreciate receiving a
layout drawing of the proposed facilities.
Due to the limitations of the existing plant site, EPA should consider
maintaining the Cumberland Township treatment plant regardless of the al-
ternative ultimately recommended. Any amount of flow removed from the Gettys-
burg plant would help to ease the problem created by the limited site. It
appears,from previous meetings and work sessions, that this situation is
preferable to Cumberland Township also.
B-4
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Gannett Fleming Corddry and Carpenter. Inc.
Mr. Thomas Slenkamp
Philadelphia, Pennsylvania
-3-
January 23, 1981
In addition to the above comments, we request EPA's consideration
of the following questions and observations'.
1. On what basis have denitrification and dechlorination fa-
cilities been included in the proposed Gettysburg (and
Cumberland, for that matter) treatment plants? DER's
requirements, which are stringent, do not require either
of these processes.
2. We would appreciate receiving information on the estimated
cost of the expanded and upgraded Gettysburg treatment
plant, including the cost of renovations of the existing
facilities, as well as the recommended renovations,
Wc trust that the comments and observations contained in this letter
will be helpful to EPA in determining a final recommendation. We would
welcome the opportunity to meet with representatives of EPA to further dis-
cuss the items in this letter.
Please contact this office if you have any questions or need clari-
fication of any of these comments.
Very truly yours
GANNETT FLEMING CORDDRY AND CARPENTER, INC
VICTOR S. KREA
Project Manager
Pollution Control Division
VSK:bfd
cc: Mr. Allen Larson, Gettysburg Municipal Authority
Mr. Edward J. Corriveau, DER, Harrisburg
B-5
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j't a#
/^2&>6>. ^4- *£&/<&<&£, t^ZeS &4? <2-a?as &>
^d^-^u/ i /TZdSaS-o ^ JZjtsrcS
#*'
J&it
MRS. STRNAO ^
1 S 445 SCHOOL .^L
LOMBARD, ILL qW§
60 MS 7BT
B-6
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LAKE HERITAGE MUNICIPAL AUTHORITY
Post Office Box 114
Gettysburg, Pennsylvania 1732 5
January 23, 1981
Mr. Thomas Slenkamp, Project Monitor (3IR60)
LIS Preparation Section
U.S. Environmental Protection Agency
Region III - 6th and Walnut Streets
Philadelphia, Pennsylvania 1910b
Dear Mr. Slenkamp:
Draft Lnvironmental Impact Statement
Gettysburg, Pa. Area Wastewater
Treatment Facilities,
December 1980
Having reviewed the above referenced Draft LIS, the Lake Heritage
Municipal Authority (LHMA) would like to take this opportunity to comment
on the wastewater treatment alternatives being offered for the Gettysburg
area with respect to Lake Heritage. These comments represent the official
position of the Authority and, as such, comprise the testimony we wish to
make record at the January 28, 1981 EIS public hearing. Our comments
follow:
Of the five wastewater treatment alternatives A through E, pre-
sented in Chapter VI of the Draft EIS, only Alternative E (with modifica-
tions to be discussed herein) is acceptable to the Authority in its
general scheme of service. Alternatives A through D recommend the utili-
zation of either holding tanks or on-site disposal systems for the
majority of the LHMA service area and are therefore unacceptable for
the following reasons:
1) The number of problems with existing on-site disposal
systems and the marginal acceptability of soils in
our area indicates to us that on-site systems do not
provide sufficient long term reliability to be con-
sidered as a viable large-scale wastewater treatment
alternative for the LHMA area. They may be useful,
however, in remote, less densely populated portions
of the service area.
B-7
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Mr. Thomas Slenkamp,
Project Monitor (3IR60)
-2-
January 23, 1981
2) Our experience with holding tanks and pump-and-
haul disposal indicates that it is labor, management
and energy intensive. Our 1981 annual user charges,
for example, are $450 and our costs under this system
are still continuing to rise even with the existing
ban on holding tanks due to our limited treatment
plant capacity.
3) DER has already indicated to EPA that it views hold-
ing tanks as a "last resort" alternative to be
utilized when no other affordable solutions are
available.
4) The Authority feels long-term, large-scale utiliza-
tion of on-site systems or holding tanks will have a
detrimental effect on property values within the
Lake Heritage area.
5) Although there are naturally some differences of
opinion, the Lake Heritage Property Owners Association
has indicated a preference for sewers over holding
tanks or on-site disposal system.
In light of the above, only a wastewater treatment alternative which
recommends sewering the immediate Lake Heritage area (segments 7 to 11, in-
clusive) and Drummer Boy Campground (segment 20) would be acceptable to the
Authority. Therefore, LIMA prefers Alternative E, but with the following
modifications and contingencies:
1) Hillside Estates (segment 19) must be added to the
initial LHMA service area. This development presently
has sewers which would convey wastewater by gravity
to the LHMA treatment plant. Under an existing agree-
ment with the developer, LHMA has reserved treatment
plant capacity for this area in exchange for the
developer's assistance in building the existing plant
and collection sewers. Additionally, once our new
plant is built and this area develops, it will be of
great financial benefit to the Authority to treat this
wastewater since relatively little capital expenditure
would be required to connect the existing sewers.
This would help assure the financial feasibility of
the overall project.
B-8
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Mr. Thomas Slenkamp,
Project Monitor (3IR60)
-3-
January 23, 1981
2) The Authority would like to have the option of provid-
ing service to segments 12, 14 and 15 as site conditions,
population density and economics best allow. Although
the EIS analysis indicates on-site disposal may be the
least cost alternative for these areas, the Authority
would like to sewer those portions where it can prove
sewers will be cost-effective. Even if left unsewered,
the questionable application of on-site systems and the
need for treatment of holding tank wastes still requires
that the new LHMA treatment plant have adequate capacity
to serve these areas in the future.
3) The Authority is concerned that the population projec-
tions and, hence, the wastewater flows, the number of
EDU's, and the required treatment plant capacity de-
picted in the EIS are too low for the LHMA service area
(now considered to be segments 7-11, 12, 14, 15, 19
and 20). We realize, however, that a determined effort
to refute these projections at this time will disrupt
the EIS process and result in additional delays in
meeting the wastewater treatment needs of the area.
For this reason, LHMA is not submitting their projec-
tions at this time, but will do so later or withhold
them providing we have some assurance from EPA that
we will not be arbitrarily held to the EIS projections
if we can prove them inaccurate in the future. If the
EPA intends to adher strictly to the EIS when deter-
mining funding eligibility and project participation,
then the Authority would want revised projections con-
sidered for the Final EIS.
In closing, LHMA would like to get on with the business of meeting
the wastewater treatment needs of our area. To do so, we are willing to work
closely with the EPA and DER to arrive at mutually satisfying solutions. We
appreciate the intent of the EIS, but believe it is lacking in the specifics
addressed herein simply because its preparers are less familiar than we with
the history and needs of our service area. We hope our position and the
points we've mentioned will be seriously considered in the preparation of
the Final Gettysburg EIS and our engineer, Gannett Fleming Corddry and
Carpenter, Inc., is willing to provide whatever support documentation EPA
may require.
Very truly yours,
LAKE HERITAGE. MUNICIPAL AUTHORITY
DAVID L. LEWIS
Executive Director
B-9
-------
Mr. Thomas Slenkamp,
Project Monitor (3IR60)
-4-
January 23, 1981
cc:
Edward Corriveau, DER
Allen Larson, Gettysburg Municipal Authority
All LliMA Board Members
Leonard Ferrara, Pres. LHPOA
Mount Joy Township
Mount Pleasant Township
Drummer Boy Campground
William Martin, Hillside Estates
Gary Hartman, Attorney LHMA
Winston Lung, WAPORA INC.
Angelo Tesoriero, GFCC INC.
B-10
-------
603 N. Union Street
Natchez, Mississippi 39120
January 26, 1981
Mr. Thomas A. Slenkamp
U.S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Slenkamp:
Thank you for the opportunity to comment on the Draft Environmental
Impact Statement for the Gettysburg, Pennsylvania Area Wastewater
Treatment Facilities. While I find the Draft EIS to be quite thorough,
I fear that a lack of safeguards and procedures for implementation
leave glaring weaknesses in the document. This is particularly
evident in the areas of archeological and historical resources
and aesthetic values. (PP. 44 & 64 respectively demonstrate this concern. )
Something needs to be incorporated in the Final EIS to insure
that proper land use controls are implemented and enforced or that
substitute measures are taken in mitigation.
On page 64 it is stated that "criteria can be developed to
evaluate aesthetics and scenic views in an orderly, disciplined
manner related to existing land use and to the 'sense of place'."
Will these criteria be developed? The Final Environmental Impact
Statement must insure again that such measures are taken and not
merely mention that they can be taken.
With respect to the alternatives, A and B are the more desireable
for reasons of cost, services rendered and least negative impacts.
Alternative A is most preferable because it offers the most protect-
ion to historical and archeological resources of the area.
Obviously, Gettysburg National Military Park is the most
important resource in the area and it must be given the utmost
protection whatever the cost and whichever alternative is chosen.
Sincerely,
Ed Merre11
B-ll
-------
PROPERTY OWNER'S ASSOCIATION
P. O. BOX 420
GETTYSBURG. PENNSYLVANIA 17325
January 27, 1981
Mr. Thomas Slenkamp, EPA (31K61)
Curtis Building
6th and Walnut Streets
Philadelphia, PA 19106
Dear Mr. Slenkamp,
After review of the Draft EIS and Appendixes for the
Gettysburg PA Area Wastewater Treatment facilities, the
Lake Heritage Property Owners Association (LHPOA) desires to
submit the comments outlined herein.
In 1975 "the LHPOA was prepared to proceed with the con-
struction of a sewage collection system and treatment plant
to serve the residences of the Lake Heritage Subdivision.
However, the Pennsylvania Department of environmental Resources
directed that work on the system be deferred in favor of a
central Gettysburg system. As a result LHPOA has been prevented,
to this day, from solving its own sewage treatment problem.
Today, in January 1981, 5 years after being held up on the
construction of our own system, we are advised by the EPA EIS
that, indeed, Lake Heritage should be sewered separately„ In
the meantime, costs have risen by at least 100%, and we s^ill
have no sewage treatment system.
As a contrasting and similar situation, the Subdivision of
Lake Mead was allowed to construct their own collection system
and treatment plant, which has been in operation since 1979,
and is probably the finest and most economically constructed
system in Adams County. It should also be noted that the system
was constructed on the basis of supplying present and future
needs of the subdivision.
By contrast, LHPOA is being asked to consider the use of
holding tanks as a permanent solution. The use of holding
tanks has been considered by authorities in the past, as a
strictly temporary solution. It has little or no precedent as
a permanent solution. Also, it would appear that the legality
of such action might be in question. It would definitely pen-
alize Lake Heritage property values in contrast with surrounding
conventionally ;'ewered dwelling units.
LHPOA wants to go on record as strongly protesting the use
of holding tanks as a permanent solution to the problem; and
questions why, in view of the thwarted efforts of LHPOA to do
the job correctly, it has even been considered as a solution.
B-12
-------
-2-
One of the most obvious deficiencies in the EIS, is the
failure to make provision for serving the entire Lake Heritage
Community. There are 1,000 lots at Lake Heritage, which are owned
by some 800 property owners, who comprise the LHPOA. Most of
these owners purchased the lots prior to 1967. Today, there are
315 dwelling units at Lake Heritage. We estimate that approxi-
mately 350 additional owners will build here eventually. Many
have applied for a building permit in the past three years, but
have been turned down, and are being turned down almost every
week, for lack of sewage service. If sewage connections were
available today, it is estimated that construction would be
started immediately on _50 or more dwelling units (under favorable
market conditions). The right of these property owners to
utilize properties, which they have owned, and for which they have
paid taxes and dues, in many cases for 14 years, is a legal
right. Efforts have been growing by these frustated owners, to
seek legal redress from those responsible for this delay.
It is therefore necessary, in an area where development has
long been completed and site ownership long established, to make
provision for the future. The EIS cost estimate makes no provision
for future needs with respect to the treatment plant. The pressure
sewer system plan would undoubtedly pass all properties, and would
be designed for future connections.
It is understood that EPA grant funding is primarily to cover
existing sewage treatment needs. Therefore in view of the manda-
tory need for future treatment, the estimated 111% increase in
present flow, and the EPA funding limitations, it is considered
that the use of sewage treatment lagoons with floating aerators
would be a logical and economical treatment solution. The initial
cost would be considerably less than a conventional treatment plant,
require no interceptor line, and could readily be sized for present
and future needs, storage, and seasonal discharge considerations.
While the low pressure system described in the EIS, when
coupled with an aerated lagoon treatment plant, would be mechani-
cally satisfactory, the anticipated completion date is not satis-
factory because of urgent current requirements for construction.
In addition, as far as is known, the availability of Epa grant
monies is uncertain today, or in 1985. (A firm DER EPA position
on this question would be appreciated.)
It is considered that a more immediate and far less expensive
solution would be in the use of high performance aerated systems
for individual dwelling units. Such units are now available.
They utilize aeration and membrane filtering, and produce a very
high quality effluent. With such units the immediate need would
be for approximately 150 units to replace existing holding tanks.
The estimated cost of these per unit with drain field is $8,000,
or a capital cost of $1,200,000. The cost to the government
(grant) would be $1,020,000 versus the S3,910,000 grant now
contemplated for a pressure system. The cost per year to the
individual user (with EPA grant) would be $257
$548 per year for the pressurized system. New dwelli g
B-13
-------
-3-
owners, "beyond the existing 315, would be responsible for the cost
of their treatment system. Existing septic systems would be
replaced at the owner's expense, if the need arose. However, no
evidence has been presented in the EIS that present septic systems
are a problem. As would be necessary with any central treatment
plant, local authoritities would be responsible for the inspection,
proper operation, and installation permits, and approval of all
individual treatment systems.
It should be noted that individual systems will eliminate
the need for extensive planning and engineering,collection
system, road repair, interceptor lines, and central treatment
plant; and, in addition, would permit immediate installations to
meet our construction requirements.
One very important aspect favoring the choice of individual
systems, is the fact that at least 150 residents, already on
satisfactorily operating septic systems, would not suddenly be
faced with an added annual cost of $548.
From the environmental and ecological viewpoint, the
individual dwelling unit treatment plant is the right solution.
Their use results in zero discharge of effluent to streams and
rivers, as contrasted with central treatment. At a time when
the supply of potable water is threatened because of extremely
dry weather, the conservation of high quality effluent for
cultivation of gardens and lawns reaches necessity.
We would expect that the foregoing would be incorporated in
the final EIS. In view of the long and costly delay encountered
at Lake Heritage by the prior denial of a central system by LER,
LHPOA would also expect prompt approval of the installation of
individual treatment units, or, as a more costly, less satisfactory
alternative, approval of the pressurized system, permitting
immediate construction and early completion. We would expect
that the long delays in construction forced upon LHPOA would be
the basis for most expeditious approval by DER and EPA, permitting
LHPOA to start construction this year, and have systems, or a
system, in operation in 1982.
Finally, LHPOA would like to draw the distinction between
LHPOA and the Lake Heritage Municipal Authority (LHMA). LHPOA is
an association of the 800 plus property owners at -uake Heritage,
and is representing their views and interests. The LHMA is really
a misnomer. It is no part of LHPOA. It is a board composed of
members from three townships, which acts on DER matters over an
area larger than Lake Heritage, without consultation with LHPOA.
The policies of LHMA are, in many instances, contrary to the
interests of LHPOA members. Specifically LHPOA wishes strongly
to protest the addition of segments 12, 14, 15, and 19 to the
Lake Heritage Area. These segments are not now included in the ids
Lake Heritage Area. These are undeveloped segments, and the
B-14
-------
-4-
property owners at Lake Heritage, who have been waiting for years
for sewer service, should not have to hear the costs and delays
associated with the inclusion of additional segments, as
sponsored by LHMA.
LHPOA is giving serious consideration to incorporating as
a Borough, in order among other considerations, to maintain
control over the water and sewer policies which affect Lake
Heritage property owners.
Very truly yours,
The Board of Directors
Lake Heritage Property Owners Association
Edward S.
By
Edward S. Fleming, P
Treasurer
B-15
-------
Sonja Y. Reisinger
R. D. #5, Wheatland Acres
Gettysburg, Pa. 173?5
January ?9, 1981
Mr. Thomas Slenkamp
E.P.A. (31H61)
Curtis Fuilding
6th & Walnut Streets
Philadelphia, Pa. 19106
Dear Mr. SlenKamp,
My husband and T attended your E.P.A, meeting January 28, 1981 at 1 P.M.
in the Old Adam? County Court House. Since my husband and I were unprepared to
testify last night, I decided to write you today, so you can enter "our opinion",
though an individual opinion, one we feel will represent most of the 150 residents
at Lake Heritage currently using Holding Tanks, as a Temporary solution to their
sewerage needs. We also feel "our opinion" will represent non-residential owners,
and some residential owners who own properties at Lake Heritage and cannot BUILD
OR SELL because of the unavailability of a feasible sewerage system.
My husband and I are currently one of the non-residential owners of multiple
lots at Lake Her.ita.r^. That clarifies our personal position, as frustrated lot
owners at Lake Heritage, unable to build or sell our lots for many years, because
of a lack of avoilblp sewerage.
With our personal position stated, we have decided to endorse your "Alternative
E." Why? As a current resident of Wheatland Acres located in Mount Pleasant
Township, our sewerage costs per year our 300.00. Your 19** vrw'ectf>d cost of
^'•8.00 p^r yo~r with the implementation of Alternative S, seems a bit high now,
but taking into account that this is a five-year projection, we have decided this
cost would be one we would try to bear. We certainly can't endorse holding tanks!
Taking into consideration only 1ii2.00 difference between Alternative A and E,
completely resolved the issue in our minds. Though we would hope you could
recommend another alternative that would be more economical for all concerned,
if our choice is only ever to be between Alternative A and E, then count our vote
for Alternative E well founded.
We .ire confident that our single vote will be joined by a multitude of others
in the same situation at Lake Heritage.
I have enclosed for your review, a copy of L.H.P.O.A. January News Letter.
Please note under the heading of "Status of Holding Tanks", the 150 members at
Lake Heritage currently using holding tanks who are faced with an increase of
90.00 this year, creating a total charge of U50.00 per year for waste water
collection. This is only 98.00 less than Alternative E. What do you think their
projected costs will be for waste water collection by 1985? I'm sure you can
see those 150 members wil,l have no trouble endorsing your Alternative E, nor
could anyone endorse future holding tank expansion, instead of Alternative E.
Thus far I have represented 1c'0 people now on holding tanks at Lake Heritage,
plus the future expansion of ?00 "Naw Homes" that can be built in the future at
the Lake, which of course, represent? our personal position, also, I have not
represented the Residential Property Owhers now on septic systems, who will be
faced with what they consider, and rightly so, an unnecessary 5ii8.00 yearly cost,
not to mention installation costs. I personally sympathize with them and wish
we could somehow ease this financial burden on them.
B-16
-------
(?)
However, we must move foreward to meet the challenges of the future. We have
not been able to go forward at Lake Heritage, this has undoubtly hurt 150 people
on holding tanks now, as well a? another 300 future new home expansions at the Lake.
This represents a total of Itf^O families as opposed to 1 £0 members currently using
septic systems, a 3-1 majority, which speaks clearly for itself.
In closing this letter, I have but one last comment. Whatever decision is made,
please don't procrasinate! Move swiftly forward!
Thank You,
Sincerely,
Bob and Sonja Reisinger
SYR/enc.
B-17
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February 2, 1981
1-Ir. Thomas Slenkamp
Environments Protection Agency
(31H61) Curtis Building
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Slenkamp:
Since I was unable to attend the Public Hearing concerning the
Federal study of regional sewer needs for Gettysburg, I am writing
this letter to ask the following questions:
1. The Gettysburg Hunicipal Authority plant east of town presently
treats the sewerage for my housing development "Twin Oaks".
What will be the additional cost to ne for each plan? The
same as projected for Gettysburg or Straban Township?
2. Everyone agrees that Gettysburg needs to update its sewerage
system. From the Federal and your point of view, which is the
best immediate plan?
3. Although I realize that the various amount of monies listed
for each plan is only an estimate, do you feel the residents
of these communities are financially able to fund these plans?
Will there be assistance provided to help with the financial
obligation for the residents?
Although I realize that you are very busy, I would appreciate
the answers to my questions since they will help me decide what
plan is the most beneficial for the least amount of expenditure.
Sincerely,
Jack F. Klein
121 Artillery Dr.
Gettysburg, Pa. 17325
B-18
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Gettysburg Municipal authority
223 BALTIMORE ST R EE T
GETTYSBURG. PENNSYLVANIA 17325
April 21, 1981
Mr. Jack F. Klein
121 Arti1lery Drive
Gettysburg, Pennsylvania 17325
Dear Mr. Kleins
Your letter to the Environmental Protection Agency concerning
the Environmental Impact Statement, being prepared for this area,
recently crossed my desk and I believe I am able to answer the
questions that you posed.
The Twin Oaks development is served by the Gettysburg Municipal
Authority and will continue to be regardless of what "Plan" is arrived
at. Of the various plans being considered there would be very little
difference in cost between them to the properties served by the Gettys-
burg Municipal Authority. It has been estimated that the average
annual sewer rental charge will be about $130.00 per year. It must
be remembered that the above figure is average, naturally some will
be considerably more, others will be less, based upon flows as deter-
mined by water consumption. For a residence, it is possible that the
annual charge for Gettysburg will be considerably less than $130.00.
For commercial properties, much more.
The best "Plan" has not yet been determined. Several prominent
factors must be considered. What do the various municipalities desire?
That is Gettysburg Borough (including Twin Oaks), Straban Township,
Cumberland Township and the Lake Heritage area. What is the most cost
effective plan? This question 1s of prime consideration to the E.P.A.
in as much as the Federal Government will be offering a grant in the
amount of 75% of the construction costs for treatment facilities. In
some cases, collection systems will be Included, and in other areas
they will not be grant eligible and must be financed by that political
jurisdiction. It is hoped that the best plan will be arrived at in the
very near future.
Financial assistance to the consumer will not be an ongoing program.
The E.P.A. Grant is up front, and the debt service, operational and main-
tenance charges in the future will have to be borne by the consumer. This
is the problem confronting Lake Heritage.
B-19
-------
I hope I have answered your questions satisfactorily and if I
can be of assistance in the future, do not hesitate to inquire.
Si ncerely,
y
-------
iebruary 2, 1981
ir. Thomas A Slenkairrp
Environmental Protection Agency OKR61)
art is Building, 6th and Walnut £ts. -
riiladelnhi , PA *9106 Jgg
„ C1 , Detroit, Ml U820£
fear Mr. Slenkamp:
mr EIS for the proposed Gettysburg, HA. Area waste water treatment facilities gave several
/ternatives. Alternative A seems to be the best seems to offer the most protection for the
•cheolo^ical andhistoric treasures and is also less costly than B or C but even Alternative
.11 not be really satisfactory unless mitieatins: measures are used. Because of the history
re of a lack of land use control it is especially necessary to have strong mitigation measures.
ere are several severe deficiencies in the Draft EoS. Page hh notes the crucial issue of
nd use controls and chapter five discusses mitigation measures BUT THKkE xS V&KI LjlTtLE
BIT A*'CE GlVEK' THAT KlTHSn LAND USE CuNTHuLS uk MiTl 'ATjluN MEASURES WxLL BE USED AND VUTHvUT
EM FUTURE uF TPS PARK AVD ±TS TkEASIPSS CuuLD BS xN JEuPArtDI.
C OF THE KSASoNSTTHAT WE AttE LOSING Su MUCH uF uUK VxTAL FARMLANDS iS THAT WHhN SiT-TSx LINKS
* expanded the land developers pore in and destroy these lands -with subdi isions and/or shopping
.Is. They do not nay the costs of these sewers and roads and unfortunately the use tax which
lid nrotect our farms in not comr-on.lt is more important to protect our country than to make a
' developersrrich.
rs truly,
• & Mrs. R Poland, Mr. at "'rs. L Harwood. Mrs. G Karpinski, Mr. & Mrs. vi Angst, Mr. «e Mrs. D Doerr,
& Mrs. C Nilkins, Mr. I Mrs. M Colette, Mrs. S Leslie, Mr. u Mrs. E Park, *r. & Mrs. r Fountain©
B-21
-------
February 2, 1981
Mr. Thomas Slenkamp (3IR60)
Environmental Protection Agency
6th and Walnut Streets
Curtis Building
Philadelphia, Pennsylvania 19106
Dear Mr. Slenkamp:
We have resided in Lake Heritage since October 1978.
We have holding tanks, as do many of the residents in this devel-
opment. After more than two years of putting up with holding tanks
I'd pay almost anything to get the sewer put in Lake Heritage.
I, along with many others, have nothing but trouble with
the holding tanks. They let ground water and rain water in as well
as leak waste water out. With situations like this, all the water
saving devices in the world won't help. I've talked with building
contractors about this problem and they suggest knocking holes in
the bottom of the holding tank or fitting a drain hose in the upper
part of the second tank so that no matter how much ground water gets
in, it will not fill up. According to them, many people at Lake
Heritage have been forced to take these kinds of steps to avoid
constant problems with sewage backing up into their homes.
I, along with my neighbors, are for sewer lines being
put in and holding tanks being abolished.
Thank you,
Steve J. Monforte
256A Thomas Drive
Lake Heritage
Gettysburg, Pennsylvania 17325
B-22
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Teeter,Teeter & Teeter
ATTORNEYS AT LAW
108 WEST MIDDLE STREET
DANIEL E.TEETER
ROBERT G.TEETER
SAMUEL E. TEETER
GETTYSBURG, PENNSYLVANIA
17325
TELEPHONE
(717) 334 - 2195
February 6, 1981
Pile No. 2881
Re: Adams County Home Builders
Association
Mr. Thomas Slenkamp
Environmental Protection Agency (3IR61) Curtis Bldg.
6th and Walnut Streets
Philadelphia, Pa. 19106
Bear Mr. Slenkamp:
As counsel for the Adams County Home Builders Association, I have
been requested to provide the following comments on your draft environmental
impact statement for the Gettysburg, Pennsylvania wastewater treatment facilities.
At its February 2, 1981 meeting, the Board of Directors of the Adams County Home
"Builders Association voted unanimously in favor of Alternative D as outlined
in the draft. A stagnating economy and unavailability of suitable building
soils in the Gettysburg area have greatly injured the growth of the community
and those employed in the building construction trades. Alternative D provides
an opportunity for reasonable growth which will in turn stimulate a considerably
depressed building trade.
Thank you for your consideration of these comments
Very truly yours,
Robert G. Teeter
Warren W. Stouck,
President, Adams County Home
Builders Association
RGTses
c/c to Adams County Home Bldrs. Assoc
B-23
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Alternative B
Alternative C
Alternative D
ternative E
MS..
Stench^ -
fret- 6
amy
The Gettysburg STP would be upgraded and expanded to accommodate
currently sewered areas plus Route 30 east in Straban Township.
The Cumberland STP would be upgraded for currently served areas. A
new Lake Heritage STP would be constructed to handle that area's
septic tank and holding tank wastes. Areas north of Gettysburg in
Cumberland and Straban Townships would be accommodated by on-site
systems.
Overall Cost $20,059,000
Gettysburg and Cumberland STP's would be upgraded to handle exist-
ing service areas only. A new land treatment system would be built
to serve Route 30 east in Straban Township. A new STP would be
constructed to handle septic/holding tank waste from Lake Heritage
homes. Areas north of Gettysburg in Cumberland and Straban Town-
ships would be accommodated by on-site systems.
Overall Cost $20,782,000
Gettysburg STP would be upgraded and expanded to accommodate
currently served areas plus portions of Straban Township along
Route 30 east and Business Route 15 north. Cumberland STP would
also be upgraded and enlarged to serve an expanded area along Route
34 north of Gettysburg. A new STP would be constructed to treat
septic and holding tank wastes from Lake Heritage.
Overall Cost $22,100,000
An upgraded/expanded Gettysburg STP would accommodate flows from
current service areas plus Straban and Cumberland Townships. The
Cumberland STP would be abandoned. The Lake Heritage community
would be sewered and served by a new STP.
Overall Cost $23,100,000
The Federal government will help to defray many of the construction
costs associated with the selected alternative. Local governments
would have to pay for remaining construction costs plus operation
and maintenance. By making some preliminary eligibility assump-
tions, EPA developed the following rough estimates of what average
households within the affected jurisdictions could expect to pay
under each of the alternatives.
0U6
Estimated 1985 Annual Household Charge by Municipality
(Costs expressed in dollars/household/year)
¦ptor m ft on*
ovm. k\l
NCVfcJ e>F TT"
Afcfifc \ THis
A£cA GQOwfl) t
ih offend T* Curt'K
Alternative
Gettysburg
Cumberland
Straban
Lake
Mt.
Heritage
Joy
A
123
253
245
406
126
B
124
274
300
461
126
C
124
274
430
461
126
D
124
312
479
488
126
E
118
267
436
548
126
B-24
-------
Environmental While there are some differences among alternatives in terms of the
Impacts environmental impacts they would produce, the differences are for
the most part minor. However, the issue of how to protect the
historic and archaeologic resources related to Gettysburg National
Park remains significant regardless of which of the wastewater
treatment alternatives is selected.
Through the EIS process, careful development of alternatives has
reduced many of the potential historic and archaeologic resource
impacts associated with the originally proposed project (which
prompted an EIS). Those remaining areas of concern are being
currently discussed between members of local, State, and Federal
governments. An agreement outlining how the historic resources
will be protected is expected to be negotiated soon after comple-
tion of a Final EIS.
What Happens Now?
The Draft EIS discusses five alternatives for improving wastewater
treatment service in the Gettysburg area. It also discusses the
impacts which would occur if any of the alternatives were imple-
mented. You should decide which of the alternatives you prefer and
how you feel about the monetary, social, and environmental impacts
of these alternatives.
The Environmental Protection Agency will hold a public hearing on
January 28, 1980 at 7:30 p.m. in the new Adams County Courthouse to
gather comments and opinions on the Draft EIS (Copies of the Draft
EIS are available for review in the Adams County Library or the
offices of the Gettysburg Municipal Authority). The review period
for the Draft EIS will remain open until February 10, 1980.
Written comments should be submitted by that date to Mr. Thomas
Slenkamp, Environmental Protection Agency (3IR61), Curtis Building,
6th and Walnut Sts., Philadelphia, Pennsylvania 19106.
After the close of the Draft EIS review period, EPA will complete a
Final EIS, taking into account and responding to the comments
received on the Draft EIS. The Final EIS will indicate a recom-
mended action based on consideration of costs, environmental
impacts, public comments, and local government positions.
Following publication of the Final EIS, each local jurisdiction
must decide which course of action they wish to pursue. If their
decisions are consistent with the recommendations of the EIS, then
applications can be submitted to EPA through the Pennsylvania
Department of Environmental Resources requesting Federal funds to
implement a wastewater treatment alternative.
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-------
DONALD M. SWOPE
HENRY 0. HEISER, HI
ROBERT L. McQUAIDE
SUSAN HOWARD SWOPE
SWOPE, HEISER & McQUAlDE
ATTORNEYS AT LAW
104 BALTIMORE STREET
GETTYSBURG, PENNSYLVANIA 17325
P O. BOX 368
TELEPHONE (7)7) 33^-213^
J. DONALD SWOPE (I907-194O)
SWOPE, BROWN 6. SWOPE (19-40-1956:
BROWN, SWOPE & MACPHAIL (1956-1966'
DONALD M. SWOPE (1966-1969'
SWOPE & FRA2EE U969- 19801
February 6, 1981
Mr. Thomas A. Slenkamp
Environmental Protection
Agency (3IR61)
Curtis Building
Sixth and Walnut Streets
Philadelphia, PA 19106
Re: EIS - Gettysburg
Dear Mr. Slenkamp:
As solicitor to both the Board of Supervisors of Cumberland Township and the
Cumberland Township Authority, we have been asked to comment on the draft EIS for
waste water management facilities in the Gettysburg, Pennsylvania, area.
After careful review of the five alternatives set forth in said study, my
clients are of the view that with some refinement alternative D should be selected
insofar as the interests of Cumberland are concerned. This preference has been made
after discussion with the Township's engineers, Buchart-Horn, and is based on the
following considerations:
1. Maintenance of control over waste water matters.
2. Sewer District 3 will continue in operation and hence a retention of
existing facilities can result in a sharing of staff as well as certain
costs.
3. Much of the equipment in the STP for Districts 1 and 2 has future utility,
and therefore it would be more economical to continue the use of such
facilities. Restated, abandoning properly functioning facilities that have
remaining useful life is not a cost effective approach.
4. There is adequate room for expansion in the STP for Districts 1 and 2.
5. Our own data (based on information extending over more than two years)
relative to effluent characteristics indicates that the B.O.D. factor
set forth in Table III-3 on page 28 should read 9.5, and the ammonia
factor less than 1.0. Thus, we believe that the Cumberland STP is not
exceeding effluent limitations for B.O.D. and ammonia nitrogen, and,
accordingly, the extent of necessary upgrading is not, in our view, as
extensive as the study envisions.
6. Under alternative E, Gettysburg will have insufficient capacity in its
STP to handle flows from Cumberland Township.
B-30
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SWOPE, REISER
-------
JCafee ^Heritage
PROPERTY OWNER S ASSOCIATION
P. 0. BOX 420
GETTYSBURG, PENNSYLVANIA 17325
February 6, 1981
Mr. Thomas Slenkamp, EPA (;5lRbl)
Curtis Building
bth and iValnut Streets
Philadelphia, PA 19106
Dear Mr. ^lenkamp,
Following the public meeting on January 28, 1981,
at which time we presented our views on the EIS, it
occurs to us that the fact that we are still an
Association of property Owners and not as yet a
municipal body, may tend to make State and Federal
Authorities discount the stated views in our letter
of January 27, 1981.
We want to assure you that we are moving toward
becoming a Borough, and plan to present this
proposal to our membership at a meeting scheduled
for April 24, 1981.
We want the direct control of water and sewer
matters, which we would possess as a Borough, and
we v/ant to deal directly with EPA and DER. We do
not want the Lake Heritage Municipal Authority to
act as our agent or spokesman in the implementing
of the solutions to the wastewater treatment
problem at Lake Heritage.
we hope that you appreciate our position, and
cooperate with us in this matter.
Very truly yours
Leonard J. Ferrara
President, L.H.P.O.A
B-32
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W HOWARD CORDDRY
JOHN R DlETZ
H BRUCE GERBER
MAURICE A WAOSWORTH
WALTER K MORRIS
J DOUGLASS BERRY
HAROLO t wadoington
JOHN E WATERS
CHARLES H KRESSl.ER
Gannett Fleming Corddry and Carpenter. Inc.
ENGINEERS AND PLANNERS
RAV F STAljFFER
F JAMES KNIGHT
C. KENNETH MYERS
GEORGE H SMITH
ROBERT j DIET?
RONALD J DRNEviCh
RUSSELL S KUNGtNSMITl
EDWARD W MONROE
DAVID ANTENUCCl
PAUL W BRICKER
WILLIAM K CORliSS JR
ROBERT A STARK
JOHN J YURICK
THOMAS R BENYO
WILLIAM C EHRESMAN
FREDERICK FUTCMKO
JAMES G HANEY
GERALD P VOEGlER
GERAlO B SPECK
ROGER J BANKS
GEOFFREY A FOSBROO*
THOMAS M RACHfORD
STEPHEN F TAl.lAN
MARLIN K ULSH
JAMES R MADARA
Charles w Pickering
WILLIAM H. ALLEN
MARCELLO H SOTO
FRANK J DONATELLI
HERMAN R START2ENBACH
PAUL E PAUL
P O. BOX 1963
HARRISBURG. PENNSYLVANIA 1 7 1 05
PHONE 7 1 7 763-72 t 1
JOSEPH W LIPSCOMB
JAMES L LONG
ANTON F MIORIN
CABLE ADDRESS: GANFLEC
TELEX 84-2375
February 6, 1981
Mr. Thomas Slenkamp, Project Monitor (3IR60)
EIS Preparation Section
U.S. Environmental Protection Agency
Region III - 6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Slenkamp:
On behalf of the Lake Heritage Municipal Authority (LHMA), we are
providing comments on the above referenced document, in support of the Author-
ity's position stated in their letter of January 23, 1981. In addition, we
have been asked by the Authority to respond to certain comments made during
the Draft Gettysburg EIS Hearing of January 28, 1981.
Specifically, with respect to Lake Heritage, we will be address-
ing hearing comments which advocated the use of individual aerobic treatment
units and on-site disposal systems.
Aerobic Treatment Units
A comment was made that "high performance aerated systems for
individual dwelling units" can produce high quality effluents disposable
on-site, at less cost than a low pressure collection system and centrailized
treatment.
It may be possible that such units are capable of high quality
effluents, but field experience indicates that they are susceptible to up-
sets resulting in poor effluents and may be prohibitively expensive to
operate and maintain. These extended aeration units require regular semi-
skilled supervision and maintenance and, moreover, still require subsurface
absorption systems for effluent disposal. They provide little advantage in
areas with tight soils, high water tables, or slow percolation rates.
Draft Environmental Impact Statement
Gettysburg, Pa. Area Wastewater
Treatment Facilities,
December 1980
B-33
dontinuoui <$ii. vie t tSinci w
-------
Gannett Fleming Corddry and Carpenter, inc.
Mr. Thomas Slenkamp, Project Monitor -2- February 6, 1981
(3IR60)
These miniature treatment plants employ the same processes and
incorporate the same operating complexities found at the Authority's exist-
ing treatment facility. A proliferation of these units would increase
annual operation and maintenance costs and result in a serious management
problem for the Authority. Additionally, these units may not be suitable
for large-scale usage due to soil limitations in the area and may eventually
constitute a health risk and pollution problem for Lake Heritage if im-
properly utilized. As with any on-site system, however, these units may
be applicable in scattered areas where site conditions are appropriate.
On-Site Disposal Systems (and Holding Tanks)
We support the Authority's position that holding tanks and a
pump-and-haul collection system is an unacceptable long-term alternative
for the Lake Heritage area. Contrary to sewers, this system offers no
economy of scale--getting increasingly more expensive to operate as addi-
tional homes are served and labor, fuel and administrative costs rise.
With 1981 user charges of $450, the future costs of an alternative depend-
ing primarily on holding tanks would be a severe economic burden on the
community.
As for on-site disposal, we share the Authority's concern that
soil limitations are generally too severe to allow their extensive usage
in the immediate Lake Heritage area, (segments 7 to 11, inclusive). Please
note that the EIS sanitary survey documenting existing on-site disposal
practices and problems neglected segments 7 to 11 and, as such, is lacking
in this regard. The EIS did indicate, however, that "Generally, soils
within the study area are not suitable for conventional septic systems.
High levels of groundwater and bedrock, and/or poor soil permeability are
soil characteristics in virtually all of the study area."
According to the local sewage enforcement officer, approximately
85% of roughly 100 lots tested for compliance with the latest standards for
on-lot disposal suitability have failed to meet the requirements for sub-
surface absorption. The remaining 15% qualified for modified on-lot systems
utilizing elevated sand mounds. Similarly, an analysis of the "Adams County
Soil Survey" indicates that soils surrounding Lake Heritage have a "severe"
limitation for disposal of effluent from septic tanks and that the depth to
bedrock, ground surface slope and/or high water limitation may also prohibit
the construction of sand mounds in certain areas.
We do not believe that the Authority is indifferent to the approxi-
mately 150 homeowners who presently utilize on-site disposal systems. A
number of alternatives in terms of system configuration, staged construction
or connection, and local funding can be examined to minimize impacts on these
users. However, the Authority's overriding concern is to meet the wastewater
treatment needs of the entire community (1100 developable lots) in a manner
which will equitably minimize costs and the potential for polluting Lake
Heritage. There are approximately 170 homeowners now paying $450/year to
B-34
-------
Gannett Fleming Corddry and Carpenter, Inc.
Mr. Thomas Slenkamp, Project Monitor -3- February 6, 1981
(31R60)
have their holding tanks pumped due to on-site disposal system malfunctions
or inadequate soils. With an additional 3S0 homes projected in the next
20 years, it is our belief that low pressure collection and centralized
treatment is the most reliable and best overall solution for the area.
Very truly yours,
GANNETT FLEMING CORDDRY AND CARPENTER, /INC.
// ve///
^>V i,
ROBERT E. SHAFFER, P/E.
Project Manager
Pollution Control Division
L
RES/AAT/dav
cc: David Lewis, Exec. Director, LHMA
Edward Corriveau, DER
Gary Hartman, Attorney LHMA
Dean Schultz, Gettysburg Engineers
Ann Hunter, LHMA
B-35
-------
League of Women Voters
OF ADAMS COUNTY
Feb. 7, 1981
attention: Mr. Thumas Slenkamp,
ihe League uf
-------
Petty Heckel
290 Dolphin Way
Lagunn Bench CA 92651
2-7-81
I,-r .Thomas -A .S1 enkamn
U.S.Environmental Protection Apency
Curt 1b Bldg.
6th aod V/alout Street
VbiTndelptaia Peon.
Bear IAr. Slenkamp.
Re.: Gettysburg,Pennsylvania Area Wastewater
Treatment Facilities.
The Draft EIS offers no assurance that measures will
be taken to raitieate the harmful effects of the newer
system on the Park.
It appears that Alternative A appears to be the best
alternative and Alternative B is the second be:.t.
It is hoped that the proposed sewer system near Gettysburg
National Military Park will not be detrimental to the
existing Park,which is a national monument f.0(3 should stay
unharmed and in the same way for generations to come.
Very truly
z < ' f y ¦ { i {
B-37
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BULLEIT & SCHULT2
ATTORNEYS AT LAW
ADAMS COUNTY NATIONAL BANK BUILDING
GETTYSBURG, PENNSYLVANIA 17325
Edward B. Bulleit
Chester Gitt Schultz
TELEPHONE (717) 334-3150
February 9, 1981
(FORMERLY BULLEIT & BULLEIT)
In re: Straban Township, Board of
Supervisors - EPA Draft
Environmental Impact Statement
for Gettysburg, Pennsylvania,
dated December, 1980.
Our file k(Jl6-C
Thomas Slenkamp, Project Monitor, Region 3
Sixth and Walnut Streets
Philadelphia, PA 19106
Dear Mr. Slenkamp:
By way of further response to the Environmental Protection
Agency Draft Environmental Impact Statement for Gettysburg, Penn-
sylvania, dated December, 1980, for the area wastewater treatment
facilities, I write to you as the solicitor for Straban Township
and on behalf of Straban Township, Adams County, Pennsylvania.
The Board of Supervisors of Straban Township had previously
outlined in their letter dated May 2, 1980, a subsequent letter to
you dated January 16, 1981, and their oral comments given by me at
the public hearing held on January 28, 1981, their previous con-
cerns as to the Draft Environmental Impact Statement of December,
1980. Further statements are warranted as follows:
1. The area to the east of the Borough of Gettysburg in
Straban Township located along U.S. Route 30 designated as Segment
I4. is considered by Straban Township to be a prime area for develop-
ment within the township.
2. Alternative B as set forth in the December, 1980, Environ-
mental Protection Agency Draft Environmental Impact Statement is
considered to be the alternative most acceptable to Straban Township
with the following limitations:
A. The capacity as presently set forth does not appear
to be sufficient to handle the needs of the segment.
B. The township has previously addressed itself to these
concerns and creations in previous letters and statements.
B-38
-------
BULLEIT 6t SCHULTZ
ATTORNEYS AT LAW
ADAMS COUNTY NATIONAL BANK BUILDING
GETTYSBURG, PENNSYLVANIA 17325
Edward B. Bulleit telephone (717) 334-3ISB (formerly bulleit s. bulleit)
Chester Gitt Schultz
Thomas Slenkamp
Pafre 2
February 9, 1981
C. This alternative comes closest to address the
concerns which Straban Township had originally raised.
3. Table III-V, Population Trends and Projections (1980-2003')
shows the population for Straban Township in the year 19o0 to be
3j57i|. According tc the most recent figures available to Straban
Township, the present population is 14.,2^8 which would put the town-
ship at approximately the level designated, and. projected for the
year 1990 ox' /.j.,357 in population. This would, indicate that these
projections are already outdated in Table III-V.
1|_. Page 133 of the Dra:ft Environmental Impact Statement as
to Alternative B states . . . "However, Segment II is not considered
to be a critical area by the National Park Service and scenic views
from the battleground historic district toward Segment Ij. were not
found to be of high quality during the 1979 aesthetic resources
survey . . . There may be some adverse effect on these views, such
an effect constitutes a secondary impact on the Gettysburg National
Military Park and battlefield historic district."
Even though it is indicated that the secondary impact as
it relates to Segment 1|. and Alternative B is not considered to be a
critical area by the National Park Service, Straban Township is
willing and has been willing in the past to consider alternatives
to minimize the secondary impacts related on Page 133 as to Alterna-
tive B in Segment 1^. One such alternative which is presently being
considered by Straban Township as a proposal is the adoption of an
historic district ordinance under the provisions of Act 167 adopted
by the General Assembly of the Commonwealth of Pennsylvania and
approved by the governor of the Commonwealth of Pennsylvania on the
13th day of June, 1961, as amended, which authorizes townships to
create historic districts within their geographic boundaries. This
legislation would authorize a township to protect the distinctive
historical character of the district and to regulate the erection,
reconstruction, alteration, restoration, demolition or razing of
buildings within the specific historic district. This would also
tend to set the limits or the boundary of the service area which
would also, therefore, be a means to control secondary impacts.
Very truly yours,
cc: Straban Township Board of Supervisors
Dean Shultz _
B-39
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COMMONWEALTH OF PENNSYLVANIA
PENNSYLVANIA HISTORICAL AND MUSEUM COMMISSION
Mr. Thomas Slenkamp
Environmental Protection Agency
(3IR 61)
Curtis Building
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Slenkamp:
The Bureau for Historic Preservation has reviewed your draft
environmental impact statement for the Gettysburg Area Wastewater
Treatment Facilities. Our primary concern pertains to the indirect
effects of this project on the distribution of growth in Cumberland
and Straban Townships. We look forward to further discussions regarding
Act 167 historic districts as mitigative measures.
WILLIAM PENN MEMORIAL MUSEUM AND ARCHIVES BUILDING
BOX 1026
HARRIBBURQ, PENNSYLVANIA 17120
March 13, 1981
Re: ER 81 001 0109
Sincerely
G^eg Ramos ey \
Architectural Historian
Division of Planning & P:
Division of Planning & Protection
Bureau for Historic Preservation
(717) 783-8947
GR:jek
B-40
-------
A Pennsylvania
State
Kit Clearinghouse
k
P.O. BOX 1323 - HARRISBURG, PA. 17120 - (717) 787-8046
783-3133
Commonwaalth
of
Pennsylvania
SOVERNOR'S OFFICE
'FlCE OF THE BUDGET
February 3, 1981
United States Environmental Protection Agency
Region III
6th and Walnut Sts.
Philadelphia, PA 19106
ATTN: Thomas Slenkamp
Dear Sir,
Enclosed are comments from the Department of Environmental
Resources concerning the draft EIS "Gettysburg, PA Area Waste-
water Treatment Facilities." Pleafee consider these the comments
of the Pennsylvania State Clearinghouse.
Sincerely,
Anne Ketchum
Supervisor
B-41
-------
v»r?.. •'
Secretary
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OP ENVIRONMENTAL RESOURCES
P. 0. Box 2063
Harrisburg, PA 17120
Review and Evaluation of PSCH No.
January 23, 1981
5-80-12-009
Draft Environmental Impact
Statement Gettysburg, PA Area
Wastewater Treatment Facilities,
Adams County
Anne Ketchum, Supervisor
Pennsylvania State Clearinghouse
<\ \
CLIFFORD L. JONES j ,:
Secretary of Environmental Resources
U-l\
The Department has reviewed the Draft Environmental Impact
Statement (DEIS) on the Gettysburg Area Wastewater Treatment Facilities
and offers these comments.
The Department has worked closely with the consultant and the
Environmental Protection Agency in preparing the DEIS for this project.
Because of this cooperative arrangement the Department has no major
problems with the DEIS contents that could not be resolved.
There is an overwhelming need for wastewater treatment facilities
in the Gettysburg Area. The recent preliminary census count summaries
for 1980 show a 20% increase in population and a 31.91 increase in housing
units in Adams County.
We should note the permits will be required under the provisions
of the Dam Safety and Encroachments Act and Floodplain Management Act
for some parts of the project. The applicant may contact Mr. Paul
Gardasick of the Harrisburg Regional Office, Bureau of Dams and Waterway
Management, 116 Executive House, P.O. Box 2357, Harrisburg, PA 17120,
(717) 783-9726 for further information.
B-42
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K^M^IETH J. COLE, MEMBER
ROUTE 1
GETTYSBURG, PENNSYLVANIA 1732B
(717) 334-1904 DISTRICT OFFICE
(717) 787-6B37 HARRJSBURG
CHAIRMAN. SUB-COMMITTEE ON HEALTH
AGRICULTURE AND RURAL AFFAIRS
MILITARY AND VETERANS AFFAIRS
COMMITTEES
HOUSE OF REPRESENTATIVES
COMMONWEALTH OF PENNSYLVANIA
HARRISBURG
February 3, 1981
Mr. Thomas Slenkamp
Environmental Protection Agency
EIS Preparation Section
6th and Walnut St.
Philadelphia, Pennsylvania
SUBJECT: Centralized Sewers/Pressure Sewers
Gentlemen:
As a resident of Lake Heritage and on behalf of the residents on
septic systems I feel that an annual user charge of $548/yr,, as
determined by the Environmental Impact Statement, is excessive for
residential sanitary sewer service.
1 was about the fifth resident at Lake Heritage and have seen
our comminity develop, and also feel that the Individuals with
septic systems should not be responsible for offsetting high cost
of holding tanks. Those individuals on holding tanks made that
decision on their own, and probably save on their capital investment
when purchasing property.
1 know of no community that pays a sewerage rate as high as
proposed here. I therefore, wish to enter this as testimony in lieu
of personal testimony at the public hearing January 28, 1981.
Lake Heritage
Sincerely,
State Representative
cc: W. F. Hill
L. H. M. A.
B-43
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814/359-2754
COMMONWEALTH OP PENNSYLVANIA
PENNSYLVANIA FISH COMMISSION
Division of Fisheries
Fisheries Environmental Services Section
Robinson Lane
Bellefonte, PA 16823
February 5,.1^81
Mr. Thomas Slenkamp tf-
U.S. Environmental Protection Agency
Region III
Sixth and Walnut Street^1
Philadelphia, PA 191Q&
Re: Draft E.I.S.
Gettysburg, PA Area
Wastewater Treatment Facilities
Dear Mr. Slenkamj):
The subject draft environmental impact statement has been reviewed
by the Pennsylvania Fish Commission and we wish to make the following
comments.
Since Qiir primary concern is with the quality of the surface water
as it relates to a possible fishery, the alternative (or alternatives)
which giv«s a desirable quality effluent without removing recharge
water frdi too large an area would be our preference; It seems that
alternatives. B and D, although they collect water from a larger area
than alternative A, will give a desirable quality effluent from the
three STPs in^QRock Creek and its tributary, White Creek.
" "' *sr
The buildif^g of a«
across the streams. in\
sewer lines in the vicinity of and
jpgjff?)®lso of concern to us. Adequate plans
for siltation control stream crossings should be
included in the studj^. ^s
JGM:dms
cc: D.. Graff
L. Jackson
be expec
Appendixes E-JV artd
E-4 is of importance fed
regulatory agency re®ppn;j
to receive a copy Oi
Thank you/tor
impact statement
statement when jo
included in the material sent to us.
ania Fish Commission since we are the
Mbians and reptiles. We would like
view the draft environmental
the final environmental impact
left G. i
p4sh«ri.as EK^onnieiifcal Services
B-44
-------
rv B¥i>:
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Bureau of Water Quality Management
407 South Cameron Street
Harrisburg, Pennsylvania 17101
(717)787-9665
February 6, 1981
Certified Mail
Sewerage
Grants
Gettysburg Borough
Adams County
Mr. Thomas Slenkamp
Project Monitor
Environmental Impact Section
U. S. Environmental Protection Agency
Sixth and Walnut Streets
Philadelphia, PA 19106
Re: Draft Environmental Impact Statement Testimony
Dear Mr. Slenkamp:
The Department of Environmental Resources has reviewed the Draft
Environmental Impact Statement (EIS) and would like to provide the following
written testimony.
The Department wishes to express its appreciation for the effort expended in
developing this draft EIS to date. We would like to impress upon all participants
the need to continue on in refining, selecting and implementing an alternative that
will solve the severe water quality problems of the Gettysburg Area while
minimizing potential secondary impacts on the historical ammenities of this area.
While the EIS has expressed quite clearly the tremendous need for improved
wastewater treatment facilities, it has fallen short in conveying guidance and
initiative back to the local level. The following comments, many of which have
been raised by other participants either in writing or testimony need to be
evaluated and discussed in the final Environmental Impact Statement.
1. An issue, which must be addressed, has been raised seriously questioning
the structural stability and usefulness of the existing Gettysburg
treatment plant.
2. There were still some uncertainties expressed during the EIS process
concerning the availability of land necessary for expansion and upgrading
at the existing Gettysburg plant site.
B-45
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Mr. Thomas Slenkamp
Page 2
February 6, 1981
3. Recent EPA draft guidelines which questions the effectiveness of the l/l
removal program means that the l/l allowance figures used in the Draft
EIS are only preliminary figures and will be confirmed upon approval of
the final l/l work.
4. The alternatives recommending replacement of or development on the
septic tank sand mound systems or overland treatment is unsupportable
based on any information we have seen either in previous grant project
submissions, in local municipal planning submissions, or in the EIS. As we
have stated previously, holding tanks may be considered a viable option
only when they are managed properly in a municipally controlled district
and when no other affordable solutions are available. The pump haul on-
lot municipally controlled district was addressed too loosely in the draft
EIS. If it is EPA's intention to recommend the pump and haul
alternative, then EPA must place greater emphasis on implementation
and defining municipal responsibilities for this alternative.
5. It was very disturbing for us to hear, at this late date, another section of
EPA raising questions concerning AWT/AST review. We trust that EPA
will communicate themselves clearly on what and how to address any
questions as efficiently as possible, being sensitive to the time
constraints of this project. As pointed out previously to you, the State
does not require denitrification and dechlorination facilities for the
Gettysburg area facilities.
6. The draft EIS report unfortunately at this point does not specifically get
at the main reason why the EIS was initiated, which is to provide the
framework for a Memorandum of Agreement (MOA) on what mitigating
measures can be implemented to minimize the possible secondary
impacts on the historical nature of the area. The Department feels that
a feasible alternative to address mitigating measure will only come
through the fostering of a spirit of communication and coordination
between the Park Service and the local municipalities. The Park Service
must take the initiative and be up front in communicating its concerns to
local developers, if any mitigating measures are to be implemented
smoothly and effectively. For this reason, the Department feels that the
MOA is basically a federal matter to develop an understanding between
federal agencies on what mitigating measures are feasible and implemen-
table. In order to be respectful of all parties involved, particularly the
tremendous need for implementing a solution to the water quality
problems in the area, some boundaries or constraints and a time frame
must be established for finalizing the MOA. Indeed, the proposed
solutions to the water quality problems of the area and their grant
applications must proceed as soon as possible and should not be delayed
while the federal matter of an MOA is resolved.
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Mr. Thomas Slenkamp
Page 3
February 6, 1981
7. The Department has mentioned previously that as the EIS draws to a
close EPA must provide for a smooth transition from the federal level
(EIS) back to the local projects. It is very important for the local
municipalities to regain the initiative in order for their needs to be met.
The Department will meet with and communicate to the municipalities
what is needed to refine the EIS to meet State Sewage Facilities Act
requirements. EPA has an obligation to communicate in writing what
may be needed to refine the EIS from a federal prospective as well as as
set up a mechanism to monitor the transition back to the local
municipalities. As suggested to the EIS project monitor, we recommend
a monthly meeting between the grant applicants beginning with the end
of February to allow for this smooth transition. This meeting must
involve all sections of EPA necessary to secure federal grant assistance.
8. We would like to acknowledge that the Department has monitored and
provided comments in writing (November I k, 1979, April 17, 1980 and
September 16, 1980) and orally during the development of the Draft EIS.
The Department would appreciate a copy of all the written testimony
received on the draft EIS report as well a written response on how EPA intends to
pursue the questions raised with our testimony.
If you have any questions concerning this matter please contact Edward
Corriveau, DER Project Manager.
FAM:EJC:jvl
cc: Gettysburg Borough Municipal Authority
Lake Heritage Municipal Authority
Cumberland Township Municipal Authority
Straban Township
Gettysburg National Park
Dennis Capella, EPA
Dick Pastor, EPA
Joe Galda, EPA
Sincerely yours,
Frederick A. Marrocco, P.E.
Regional Water Quality Manager
Harrisburg Regional Office
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Advisory
Council On
Historic
Preservation
1522 k Stnuit. NW
Washington. DC 20005
Mr. Jack J. Schramm
Regional Administrator
U.S. Environmental Protection Agency
Region 111
6th and Walnut Streets
Philadelphia, PA 19106
Dear Mr. Schramm:
The Council has reviewed your draft environmental impact statement
(DEIS) for Gettysburg Area Wastewater Treatment Facilities, Adams
County, Pennsylvania, circulated for comment under Section 102(2)(C) of
the National Environmental Policy Act of 1969. As you know, the Council
has had an ongoing involvement in the consideration of various proposals
for wastewater treatment in the Gettysburg, Pennsylvania, region. Amy
Schlagel of our staff has been participating on the Interagency Coordinating
Group. We have been concerned about project impacts on the numerous
historic and cultural properties in the area, including those resources
associated with the Gettysburg Battlefield Historic District, a property
included in the National Register of Historic Places. As your staff is
aware, our concerns have included both potential direct (primary) and
indirect (secondary) impacts of the proposed project. We have, therefore,
divided our comments on the DEIS into the two following sections.
Primary Impacts
The DEIS contains a good discussion of potential primary impacts on
historic resources in the planning area. We would encourage EPA,
however, to pursue further planning and design of facilities like the
proposed pumping station on the Cumberland Township border northwest of
Business Rt. 15 (p. 131), in order to minimize the visual and construction
impacts of such project facilities on both historic sites adjacent to
the National Register Historic District and individual structures within
it. Landscape screening and below-grade construction (p. 134) to help
mitigate visual impacts are good first steps, but such measures need
considerable design work and refinement.
The sections addressing primary project impacts on archeological resources
must be updated. It is unfortunate that the archeological reconnaissance
performed by Kinsey (1979) was both preliminary and corridor-specific.
As the National Park Service has previously pointed out, discussion of
the archeological potential (both prehistoric and historic) of the
entire planning area would substantially assist in the 201 planning
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effort. If construction is proposed along the portions of Rock Creek
and in sewage treatment plant expansion areas which Kinsey identified as
having "low" archeological potential, we recommend that some additional
geological and/or archeological investigations be carried out in order
to verify Kinsey predictions. Nothing is known of the alluvial history
of Rock Creek, and the low marshy areas may be relatively recent. In
addition, as the National Park Service has indicated, Kinsey did not
consider the presence of possible historic archeological resources in
these areas. In any event, detailed, intensive archeological survey and
testing will be necessary when an alternative is chosen. This should
include 100% survey of interceptor corridors, treatment plant expansion
areas, and pumping stations, along with subsurface testing. Survey and
testing should be scheduled as early as possible during Step II, so that
there will be enough time for the results to be taken into account in
both line alignment and in carrying out any necessary mitigation activities.
Indirect Impacts
The most serious problems with the DEIS stem from our concern with the
potential indirect effects of wastewater treatment facilities and
associated future development in Adams County. Under "Aesthetic Resources,"
the DEIS states that existing historic preservation legislation provides
for "consideration of primary effects on historic cultural resources,"
but that "such consideration would not be required for privately-funded
future development (secondary effects) in planning area" (p. 135). This
is incorrect. Section 800.3(a) of the Council's regulations, "Protection
of Historic and Cultural Properties" (36 CFR Part 800) , clearly states
that it is the responsibility of Federal agencies to consider both the
direct and indirect effects of its undertakings. This section should,
therefore, be corrected.
In general, the discussion of potential indirect impacts throughout the
DEIS is non-specific and somewhat confusing. We do not understand the
statement on page 135, as repeated from page 130, which notes that "none
of the alternatives would induce growth or development beyond what would
occur without the proposed Federally-funded project." While this may
indeed be true for the overall magnitude of growth, it is doubtful
whether it is true for the distribution of that growth. It should be
possible to get some better understanding of where population will tend
to cluster under each alternative. The very brief discussion of possible
induced growth effects under each alternative (p. 135) is helpful, but
more analysis is needed. Simple reference to the Council's report on
Gettysburg (which we understand is the missing Appendix G-8) adds little
to the discussion in this regard. We wish to reactivate our participation
in the EPA-sponsored interagency coordinating group, and join in any
future meetings. The focus of the group's discussions since the beginning
of revised project planning has been on lands adjacent to the historic
district and outside National Park Service managed property. We agree
that further discussions should be focused on these adjacent lands,
particularly on development in Cumberland and Straban Townships (p.
125). Development in these areas may in fact prove to be more compatible
with the long-range planning goals of the National Park Service, as the
DEIS recognizes (p. 126).
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We hope these comments will be helpful to you, and we would be pleased
to discuss our concerns or suggestions for possible mitigating measures
in further detail. Please contact Amy Schlagel at FTS-254-3495.
Thank you.
Sincerely,
Jo
Ch
of Project Review
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United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
FEB 2 0 1981
Mr. Jack J. Schramm
Regional Administrator, Region III
Environmental Protection Agency
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
Attention: Mr. Thomas Slenkamp
Dear Mr. Schramm:
The Department of the Interior has completed its review of the draft
environmental impact statement (DEIS) for wastewater management facilities
in the Gettysburg, Pennsylvania area. Our comments are presented below by
our areas of jurisdiction and special expertise.
NATIONAL PARK SYSTEM AND THE NATIONAL REGISTER OF HISTORIC PLACES
The Department of the Interior supports efforts to improve wastewater
management in the Gettysburg, Pennsylvania area. However, the DEIS
fails to provide an analysis of impacts and alternatives for the ensuing
development of the project areas, from the standpoint of the proposal's
potential impacts on Gettysburg National Military Park and Gettysburg
National Cemetery.
As presented the alternatives are difficult to differentiate, especially
in how they rank regarding impacts on National Park Service concerns.
Attention to development opportunities, in segments 2, 3, 4 and 18 is also
limited to corridors along major highway routes. Discussion is necessary
on the possibility for expansion of service to development outward from
these segments and corridors. The relationship between the segments
and the Park and Historic District areas should also be clarified through
improved graphics.
The DEIS states that it may be difficult for EPA to provide adequate
mitigation for secondary impacts due to the presence of privately funded
future development in the planning area. Consideration of mitigation
alternatives, however, is mandated by historic preservation legislation,
as well as by the National Environmental Policy Act. In this regard, the
document referenced for further detail on mitigative measures, Appendix G-8
(pages 134, 137), is omitted from the Appendix volume. It is our under-
standing that Appendix G-8 represents the Advisory Council on Historic
Preservation's report on a variety of possible mitigation measures.
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This report does not, however, provide an analysis of the likely impacts
of the mitigation measures proposed. The final statement should focus on
the details of mitigation for primary and secondary impacts. While the
draft EIS has been responsive to certain of the National Park Service's
earlier concerns, it does not provide an adequate description of likely
impacts for the potential development of the project areas (segments) in
question.
Background
The following brief, early history of the Battlefield is offered to
illustrate the longstanding concern that the nation has had for the site
of the battle. Over the years much has been invested in terms of individ-
uals' personal efforts, and private and public funds, to preserve the
Battlefield. This interest is ongoing.
The significance of the events at Gettysburg was perceived almost
immediately. Local efforts to preserve the battleground were launched
within days of the armies' withdrawal. Six weeks after the great battle,
the first purchase of commemorative lands occurred. The 17-acre cemetery
was purchased with funds that came from the legislatures of certain
states represented at the battle. On November 19, 1863, President Lincoln
came to Gettysburg to attend the dedication of the Soldiers Cemetery, and
at the ceremony gave bis immortal Gettysburg Address.
Battlefield preservation continued under the War Department, which
administered the Cemetery, and the Gettysburg Battlefield Memorial Assoc-
iation incorporated in April 1864. In 1865, the Gettysburg National
Military Park was established by Federal legislation. Later in 1896
in a landmark decision, the U.S. Supreme Court upheld the right of the
Secretary of War to condemn a portion of the battlefield threatened by
private development, for the purpose of protecting it for the "use and
inspiration of all Americans." It was at Gettysburg that the concept
of the taking of private lands for historical purposes was first tested
and upheld.
In addition to an annual park operating budget of 1.4 million which
covers salaries, maintenance and restoration work, there is a large
public capital investment within the park. In addition, the Commonwealth
of Pennsylvania estimates that $50 million is generated annually from
tourism in the area. Because of the uniqueness of Gettysburg, it is
difficult to quantify all of the values that the National Park Service
is committed to protect; these figures give some sense of the magnitude
of present Federal involvement in the area.
Since the 1963 Civil War Centennial Celebration at Gettysburg there have
been several planning efforts focused on preserving the area's historic
character, scenic and environmental values. The National Park Service
is currently preparing a new development/master plan for the park.
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The controversy surrounding the Gettysburg Tower also spawned several
planning studies. Special Federal funds were provided for the Gettysburg-
Cumberland Demonstration Project 1969-71, prepared by Wallace, McHarg,
Roberts and Todd. The Pennsylvania Department of Community Affairs has
devoted considerable attention to Cumberland Township in working with
that municipality to prepare a township plan. In its 1977 report the
Advisory Council on Historic Preservation identified 916 acres of land as
critical to the integrity of the battlefield and recommended National
Park Service acquisition of those lands.
Throughout these efforts the National Park Service objective has been to
protect the scenic/visual values of the historic battleground setting
through cooperative efforts with local communities. The National Park
Service has participated fully in the studies noted above, and is still
working with local communities to meet its objectives of protecting the
Battlefield setting.
Discussion
The alternative actions evaluated would facilitate centralized sewage
service to varying numbers of segments or service areas. These segments
are delineated with approximate boundaries, but no information is presented
on how each segment is likely to be developed. In the absence of any
proposed actions which would regulate or mitigate effects of growth, we
must assume a worst-case situation. Such a "worst-case" assumption would
be of particular concern to NPS for segments 1, 2, 3, 4, 17 and 18, in
which adjacent development has the most potential for adversely impacting
the historic scene surrounding the Park and Cemetery. Even in these
areas, however, we believe that with consideration given to proper
siting, screening, and density-and type of building, these adjacent lands
could be developed without undue adverse impact to NPS areas. Without
such safeguards, the park and cemetery could be impacted quite seriously.
Should EPA fail to consider an array of mitigation measures within these
proposed development areas, we believe NEPA compliance will be inadequate.
At a minimum, these mitigation measures should be included in the final
EIS; and only after further consultation with the National Park Service.
We recognize that actual implementation of such mitigation measures is a
difficult challenge. Ultimately, achievement of effective land use
patterns at the various areas proposed for sewer development will have
to be a joint effort by all parties concerned. Such an approach will
be the. only way to ensure that both the Federal and the state and local
concerns at Gettysburg can be brought Into balance.
Without such a joint venture, Gettysburg will have continued conflict
between the need to protect the nationally significant park area and the
legitimate concerns of the local community for growth and development.
This situation was clearly articulated by Judge MacPhall of the Adams
County Branch of the Court of Common Pleas 1n his October 26, 1971
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opinion refusing to enjoin the construction of the Gettysburg Tower.
The key passage is as follows:
"We have emphasized "present-day Gettysburg" in our
discussion thus far because much as we may like to deal
with things as they should be or even have been, we
must view the situation as it now exists. The evidence
in this case clearly shows that the historical
Gettysburg area has already been raped. A major
highway bisects the fields of Pickett's Charge. A
Stuckey's restaurant, a motel and an ice cream parlor
face the Peach Orchard. A souvenir stand flourishes
near a government observation tower opposite the
Eisenhower farm. These are but a few examples. The
Federal government's only recourse in the past has been
to purchase these sites as funds become available.
Then, of course, new ventures start elsewhere in
equally offensive locations. Those who are so
vociferous in their protest against the commercialism
would be well advised to transmit their feelings to
local officials and insist upon the enactment of
appropriate ordinances and the adoption and
implementation of comprehensive plans for the entire
area. Since all of the people of this nation,
including "generations yet to come" have a stake in the
outcome, this must be a joint venture among the
Federal, state and local governments. It is
encouraging to note that at last there is a
comprehensive plan for the future development of the
Gettysburg National Military Park and that, since this
case was instituted, efforts have been initiated on a
state and local level to plan for the future
development of this historical area. In the meanwhile,
however, the courts cannot be used as a substitute for
the legitimate exercise of police power by the local
governments, and unless there is a clear showing of
irreparable damage, the extraordinary remedy of
injunctive relief cannot be, and will not be, invoked."
Opinion of the Adams County Branch of the Court of
Common Pleas of the 51st Judicial District in and for
the Commonwealth of Pennsylvania (MacPhail, J.) at 13 & 14.
Judge MacPhail essentially concludes that the threats and intrusions to
the park are there because the park is there; that the traditional
National Park Service approach of purchasing various threatened
areas is not a permanent solution; that the real solution is a "joint
venture among the Federal, state and local governments"; and that the
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courts cannot be used as a substitute for the legitimate exercise of
police power by the local governments. This is a concise and accurate
summary of the situation presently confronting the Gettysburg National
Military Park. It is as true today as when it was written.
The need to promote constructive dialogue over land use decisions affecting
local communities adjacent to the Battlefield has long been noted. A
decision to go forward to construct wastewater facilities without considera-
tion of types of induced development or land uses adjacent to the park would
fail to give the National Park Service any assurance that land use impacts
would be governed by compatible practices, standards or design measures.
Tract-by-tract actions by NPS in the absence of such considerations
promote an adversary relationship when NPS moves to protect the park
from adverse impacts and the local community sees such development as
necessary for expanding their tax base.
We request that EPA consider the alternative impacts that will be set in
motion within the proposed sewer areas discussed above, depending upon the
type of development that will occur. The true environmental impact of this
project can only be evaluated from this perspective; we believe this is
required by NEPA and the CEQ regulations. We also encourage EPA to con-
sider the joint preparation of development guidelines to be adopted and
enforced by the affected community as a part of their grant process. In
this manner the existing Federal investment and role at Gettysburg will
not be compromised by the EPA project in question. Careful planning
now -- as a joint effort — can avoid needless and ineffectual confrontations
in the future.
FISH AND WILDLIFE RESOURCES
General Comments
The draft EIS (DEIS) does not indicate whether or not the project as planned
would require Federal permits under Section 404 of the Clean Water Act
of 1977. If proposed stream crossings are covered under Nationwide permits
(33 CFR 303.4-2 and -3) we recommend that the work be undertaken in full
compliance with the standards described in the Nationwide permit. If
further action is needed for either 404 or National Pollutant Discharge
Elimination System (NPDES) permitting, the Department of the Interior
reserves the right to either oppose, or negotiate differences on, permit-
related matters that deal with either stream crossings or the integrity
of the National Military Park.
Detailed Comments
Pages 31-32: In the discussion of existing terrestrial biota, reference
is made to appendices E-3, E-4 and E-5, dealing with flora, amphibians/
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reptiles and mammals. No such appendices were included in the document
we received. Appendices E-l and E-2 adequately cover the existing aquatic
fauna in the study area.
Page 79: Marsh/pond systems are mentioned as one alternative means of
disposing of treated sewage plant effluent. Depending on their size,
depth and land use adjacent to them, such artificially-created wetlands
could benefit a variety of wildlife, including migratory waterfowl,
wading birds, pheasant, songbirds, muskrat and raccoon. Because of
these potential advantages to area wildlife, we believe the EIS should
explain why marsh/pond systems are considered less feasible and more
costly than overland flow, as stated at the bottom of the page.
Page 82: According to the last paragraph, the analysis of need for
improved wastewater treatment emphasized septic system malfunctions
and sewage treatment plant problems rather than well water contamina-
tion, soil suitability for septic systems, lot sizes or projections of
population growth. We believe that this is a sensible approach. Con-
sequently, we are puzzled by the fact that each of the six alternative
plans summarized in Table IV-6 (page 88) includes construction of a new
Lake Heritage sewage treatment plant, construction of sewers in that
community, or both. These proposed modifications seem unjustified, con-
sidering information presented elsewhere in the DEIS:
-The existing Lake Heritage STP is operating at about only 50
percent of its capacity and is producing an effluent that is
clear, odor-free and well within the requirements of the
discharge permit (page 70).
-There is no evidence of malfunctioning on-site systems in the
currently unsewered Lake Heritage community (page 83).
Page 116: The second paragraph states that a phosphorus concentration of
1.0 mg/1 is "acceptable in the free-flowing water, from a eutrophication
point of view." This concentration is twice the existing effluent
limitation for Gettysburg and Cumberland STP (Table III-3, page 28), and
10 times the phosphorus water quality criterion for the Rock Creek watershed
(Table III-4, page 28). It seems odd that the Environmental Protection
Agency deems acceptable a phosphorus concentration that far exceeds
established standards. Even if the existing effluent limitation
(0.5 mg/1) is maintained by new or upgraded STPs, the Rock Creek
phosphorus criterion (0.1 mg/1) will be exceeded for about 5 miles
downstream from Cumberland STP (See Figure V-2, page 117).
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Page 119: The penultimate paragraph states the "wildlife habitat is
concentrated in forest areas and forest loss is nearly equal to habitat loss."
This statement seems misleading since wildlife habitat includes all vegetated
land -not merely woodland. In this connection we believe the EIS should
contain estimates of the acreage of forest, agricultural land, etc., that
would be impacted by each alternative. This information would add an
important perspective to the ecological evaluation of alternative plans.
Page 139: We disagree with the last sentence in the penultimate paragraph.
All alternative plans for wastewater management in the study area are
scaled for human populations larger than those that now exist. The
alternative plans would accommodate a population increase from 47
to 1170 in Segment 17 and from 105 to 951 in Segment 18 (Table IV-7,
page 95 and third paragraph, page 96). Both planning segments are
characterized (Table IV-3, page 83) by malfunctioning on-site septic
systems and soils that are unsuitable for conventional on-site systems.
The plans also accommodate a population increase of 811 in the Lake
Heritage development, which likewise has soils unsuitable for conventional
on-site systems. Induced growth, even if referred to euphemistically as
"projected baseline population", will decrease the acreage of wildlife
habitat in the study area. This fact should be made explicit in the EIS.
MINERAL RESOURCES
The proposed wastewater management facilities will have no significant
impact upon mineral resources or their availability.
AESTHETIC AND RECREATIONAL RESOURCES
A number of the stations selected for classifying scenic views are not
pertinent to the segments under consideration within the DEIS. Some that
are presently classified as compatible with the historic/aesthetic integrity
of the Park and Historic District may become incompatible through foreseeable
development in the near future. Additional analysis is appropriate, on
what effect the anticipated development in the project segments will have
on the significant views of the Park and District. The aesthetic study should
also be improved by considering additional significant view points as seen
from the Battlefield tour route and historic routes entering Gettysburg.
Pursuant to the Clean Water Act of 1977, Section 201, the final statement
should consider project impacts on recreation and the potential of the waste-
water treatment facility to provide recreational and/or environmental
education facilities. The 1977 Memorandum of Understanding between the
Environmental Protection Agency and the Department of the Interior encourages
such consideration. The State Liaison Officer who is responsible for the
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Statewide Comprehensive Outdoor Recreation Plan can provide further information
on recreation proposals for the Gettysburg area. The State Liaison Officer
for Pennsylvania is Clifford Jones, Secretary of Environmental Resources,
P. 0. Box 2063, Harrisburg, Pennsylvania 17120.
SUMMARY COMMENTS
We appreciate the opportunity to comment on this proposal and look forward
to working with you in ensuring that wastewater treatment facilities
planned and implemented in a manner that protects the environment of
Gettysburg National Military Park, Gettysburg National Cemetery and the
Gettysburg Battlefield Historic District.
While we believe that all matters of concern to us can be resolved to our
mutual satisfaction, including the compatibility of development adjacent
to the National Military Park, we recognize that a significant amount of
coordination will be necessary before release of your final EIS. The office
assigned responsibility for coordination of the Department's interest in this
project is the Regional Director of the Mid-Atlantic Regional Office of the
National Park Service, 143 South Third Street, Philadelphia, Pennsylvania 19106,
telephone (215) 597-7013. We urge that you contact them as soon as possible
to initiate discussion.
S. HOFFI^NN
»iai.,Assistant to
Sincerely,
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DEPARTMENT OF HEALTH AND HUMAN SERVICES
REGION III
3535 MARKET STREET
PHILADELPHIA, PENNSYLVANIA 19101
PUBLIC HEALTH SEHVICE
MAILING ADDRESS
P O BOX 13716
PHI LADE LPHIA
PENNSYLVANIA 19101
February 11, 1981
Mr. Thomas Slenkamp
U.S. Environmental Protection Agency
6th and Walnut Streets
Philadelphia, PA 19106
RE: DEIS - Gettysburg, PA
Wastewater Treatment Facilit:
Dear Mr. Slenkamp:
Thank you for the opportunity to review and comment. We are responding
on behalf of the Public Health Service. Our comments are:
1. The document is well prepared and contains adequate justifications
to the need to improve the water quality by eliminating water
pollution problems in the study area. We are impressed with your
success in obtaining community participation in the planning
process.
2. Since the historical and archaeological importance of the area
is significant, we would like to recommend that as a spin-off of
the improvements to the sewerage system the Public Advisory Group
and/or the other committees embark in the adoption of zoning
ordinances to guide the future growth of the area.
3. The solution to the problem of illegal greywater (26% of the
systems, Page 72) should be addressed in the final EIS.
Please provide us with a copy of the Final Environmental Impact Statement.
Sincerely,
McDonald
Ji. McDonald Rimple, M.lK
Assistant Surgeon General
Regional Health Administrator
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O,
>
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
PHILADELPHIA REGIONAL OFFICE
CURTIS BUILDING, SIXTH AND WALNUT STREETS
PHILADELPHIA, PENNSYLVANIA 19106
=> *
REGION III
3CE
Mr. Thomas Slenkamp
Project Monitor
Environmental Protection Agency
Region III, Curtis Building
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Slenkamp:
We have completed our review of the Draft EIS for the Gettysburg,
Pennsylvania Area Wastewater Treatment Facilities and have no
substantive comments to offer.
Thank you for the opportunity to comment.
Sincerely,
Thomas C. Mploney V
Regional Administrator
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AREA OFFICES
Baltimore, Maryland - Philadelphia, Pennsylvania • Pittsburgh, Pennsylvania - Richmond, Virginia - Washington, O.C.
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United States
{LJlJ i Department of
Agriculture
Soil
Conservation
Service
Box 985
Federal Square Station
Harrisburg, Pennsylvania
17108
February 4, 1981
Mr. Thomas Slenkamp
U. S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, PA 19106
Dear Sir:
In accordance with CFR 650.20, we have reviewed the draft EIS for the
Gettysburg, Pennsylvania, Area Waste Water Treatment Facility and have
the following comments.
L. Soil Suitability or Limitations.
The time of year that construction of sewerlines occurs is
important because of seasonal high water tables in some of the
soils in the project area.
2. Erosion and Sedimentation Control Provisions.
Contour grading is not applicable to this project because the
sewerline rights-of-way are only 10 feet wide.
Displaced soil should not be hauled away until maximum compaction
of backfill material is obtained.
The E&S Control Plan should include a project time frame,
construction sequence, and temporary and permanent stabilization
specifications. Straw bale barriers should be installed according
to PennDOT standards. Mulches should be used according to
guidelines in the current PSU Agronomy Guide or SCS Technical
Guide, Sec.IV. Standard /M84.
3. Conservation Management Measures.
More detail is needed about the impact of sewerlines on the stream
corridors. Will riprap be necessary where sewerlines are adjacent
to outside turns in streams? If so, how will the impact on the
aquatic ecosystem be mitigated?
4. Effects of Water Discharges.
A storm water management plan should be prepared for the proposed
treatment plants.
yV The Soil Conservation Service
C jj 18 an a9encyot ,he
Department ol Agriculture
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5. Effects of Disruption of Natural Drainage and Severance of Private
Land Units.
Insignif icant.
6. Impact on Existing Conservation Systems.
Sewerlines will parallel streams in some places. Therefore,
outlets for subsurface drainage systems will be disrupted. These
should be replaced as soon as possible.
7. Impacts on Prime and Unique Farmlands:
The projection of future developments which might affect prime
agriculture land are based on the assumption that land use
regulations will not change. This may not be valid, because of
increased public interest in preserving agriculture land. Latamore
Township, for example, though not in the study area, recently
decided to study the possibility of developing an agriculture
district.
8. Impacts on Ecosystems.
There will be temporary adverse effects on streams in the study
area from erosion and sedimentation resulting from the
construction. This can be minimized by well planned and executed
E&S measures. In the long run, the project will have beneficial
effects on water quality and aquatic life. This will be accom-
plished by reducing pollutant levels in sewage effluent and by
eliminating many individual onsite septic systems, 12% of which now
fail and 26% of which now have illegal greywater separation.
Alternative A seems to be the best alternative in terms of the
terrestrial and aquatic ecosystem. Alternatives E and F would have
the greatest adverse impact on existing streamside vegetation.
The plan of "Jacking" sewer pipe under streambeds appears to be
sound and would have a minimum impact on the aquatic ecosystem.
We appreciate the opportunity to comment on this project.
Sincerely,
Graham T. Munkittrick
State Conservationist
cc:
Norman A. Berg, Chief, SCS, Washington, DC
Arthur B. Holland, Acting Director, NTSC, SCS, Broomall, PA
B-62
-------
**,wr O,
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
WASHINGTON, D.C. 20410
OFFICE OF THE ASSISTANT SECRETARY
FOR COMMUNITY PLANNING AND DEVELOPMENT
N REPLV REFER TO:
Mr. Jack J. Schramm
Regional Administrator
United States Environmental
Protection Agency - Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Schramm:
Subject: Draft Environmental Impact Statement
Gettysburg, Pennsylvania Area
Wastewater Treatment Facilities
Thank you for providing us the opportunity to review the above draft Environ-
mental Impact Statement (EIS). In accordance with 24 CFR Part 50 Protection
and Enhancement of Environmental Quality, Department of Housing and Urban
Development procedures, particularly Section 50.61 of our Regulations, we are
forwarding the EIS to the responsible HUD Regional Environmental Officer. He
will review and comment as appropriate, directly to you by your due date.
If non-HUD EIS's are sent directly to the Office with review responsibility, it
would assure more prompt and thorough review. You should send copies of all
future EIS's as follows:
1. All EIS's on legislative proposals, regulations, or policy documents of
national or multi-state programmatic significance are reviewed by HUD
Headquarters and should be sent to Mr. Richard H. Broun, Director, Office
of Environmental Quality, HUD, Washington, D. C. 20410; and
2. All other site specific activities or project EIS's should be forwarded to
the appropriate HUD Regional Office for comment. We have enclosed a list
of our Regional Environmental Officers and their addresses.
If you have any questions in this regard, please feel free to contact me at
(202) 755-6300.
Sincerely
"Richard H. Broun
Director
Office of Environmental Quality
Enclosure
B-63
-------
Region I David Prescott
Environmental Officer
Department of Housing
& Urban Development
John F. Kennedy Building
Room 800
Boston, Massachusetts 02203
Region VIII Walter Kelm
Environmental Officer
Department of Housing
& Urban Development
Executive Tower Building
1405 Curtis Street
Denver, Colorado 80202
Region II Marvin Krotenberg Region IX
Environmental Officer
Department of Housing
4 Urban Development
26 Federal Plaza
New York, New York 10007
Region III Larry Levine
Environmental Officer
Department of Housing Region X
4 Urban Development
Curtis Building
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Region IV Ivar Iverson
Environmental Officer
Department of Housing
4 Urban Development
Richard B. Russell Federal Building
75 Spring Street, S.W.
Atlanta, Georgia 30303
Region V Harry Blus
Environmental Officer
Department of Housing
& Urban Development
300 South Wacker Drive
Chicago, Illinois 60606
Region VI Otis Trimble
Environmental Officer
Department of Housing
& Urban Development
221 W. Lancaster Avenue
P.O. Box 2905
Fort Worth, Texas 76113
Dale James
Environmental Officer
Department of Housing
4 Urban Development
450 Golden Gate Avenue
Box 36003
San Francisco, California
94102
Ry Tanino
Environmental Officer
Department of Housing
4 Urban Development
3003 Arcade Plaza Bldg.
1321 Second Avenue
Seattle, Washington 98101
Region VII Gary Ultican
Environmental Officer
Department of Housing
& Urban Development
Federal Office 3uilding
911 Walnut Street, Room 300
Kansas City, Missouri 64106
B-64
-------
NTCA
BOARD OF T RUST F t 5
OFFICERS
I, II HE H T I S1U( M H
MJ'iFMF CI AH h
^ JIMVl HMAN
MEMBERS
VAUV H AMBHOSf
0«l W HLK.HHf ISHK
j()»N F tAHHOLL
, UnihrX'i N»«rH«m|,»h,
FiOBf HT C COOK
Wwhmgion. D C
JOHN I. GE0HOt
HAHHY G M JOPSON
H' i(!<|ewa1t*r Virljiiiu
. OAHWIN LAMBERT
'.:>ABELLE LYNN
Gftow W4Mi>nyn...
Stephen mathe « Mi-phe hson
N*w Ynrk, N»«m Voik
I AW At NCI C MERF1IAM. Jfl
, Lf (JNS MINCKUR
ftl.nfc»b«rO. V»(|>nM
(V\,ilUAME OOlJM
Ch»
-------
Mr. Thomas A. Slenkamp
January 15, 1981
Page Two
be put into practice. Based on the area's history of a lack of
land use control, it is likely that few, if any, of the mitigation
measures will actually see any widespread use.
Therefore, in order to make this EIS process worthwhile, EPA
must find a way to make sure that the archaeological and historical
resources are protected. One way would be to condition any
further Section 201 grants by requiring the responsible agencies
and the localities to adopt necessary mitigating measures.
A possibly more productive way would be to enter into negotiations
now with the agencies and localities and have them adopt the
measures voluntarily. Anotner approach would have EPA act as a
mediator among the interested parties and help them develop
memoranda of understanding listing the actions which will be taken.
Any of these approaches could be successful. It is imperative
that some action be taken now so that adequate assurances are
provided.
We would recommend that in the Final EIS that a map be included
v/hich shows both the segments being planned for and the boundaries
of Gettysburg National Military Park. Such a map would make it
easier for the reviewer to visualize the potential adverse effects
from development on lands adjacent to the Park.
With respect to the alternatives, we believe that the first
three, A, B, and C, are the best for several reasons. They offer
the greater likelihood for protecting the Park's resources at
least cost for the users. Alternative C is significantly more
expensive than A or B for Straban and, therefore, is likely to
be less acceptable. Alternative A appears to be preferable to
Alternative B both because it is less costly and because it
seems to offer more protection for archaeological and historic
resources. We will be examining these two alternatives in more
detail and if our preference changes, we will notify you prior
to the close of the comment period.
However, regardless of which alternative is chosen, assurances
must be given that mitigating measures will be used. Unless
this is done, a major purpose of this EIS process, the protection
of the resources of Gettysburg National Military Park, probably
will not be fulfilled. We would be pleased to offer any assistance
we can to help ensure the protection of these nationally signi-
ficant resources.
Sincerely,
William C. Lienesch
Assistant Director
Federal Activities
B-66
-------
FEDERAL EMERGENCY MANAGEMENT AGENCY
REGION III
CURTIS BUILDING
6»h and WALNUT STREETS
PHILADELPHIA, PENNSYLVANIA 19106
January 15, 1981
Mr. Thomas Slenkamp
EIS Preparation
U.S. Environmental Protection Agency
Region III
Curtis Building
6th & Walnut Streets
Philadelphia, PA 19106 Re: Draft EIS, Gettysburg, Pa.
Wastewater Treatment Facility
Dear Mr. Slenkamp:
We have reviewed the above referenced Environmental Impact Statement and offer the
following comments:
None of the various alternatives for wastewater management considered in the EIS
appear to conflict with legislation or policies for which this office is responsible
in an enforcement or consultative capacity. Our primary concern in a discussion of
the provision wastewater treatment facilities is compliance with Executive Order
11988 (E.O. 11988) Floodplain Management.
A reading of the EIS leads to the inference that the intent of E.O. 11988 will be
honored by the various alternatives. Mitigation of the primary effects of the con-
struction of collection systems crossing watercourses appear to have been adequately
addressed in Chapter V (p. 113). Secondary effects in the form of development of land
in floodplains because of the provision of wastewater treatment capacity apparently
are not expected. County and local subdivision regulations generally prohibit or
limit development in floodplains (p. 43). In addition, the amount of growth generated
by each of the alternatives does not differ significantly from projected baseline
conditions (p. 123), although the location of land required to accommodate growth
may differ.
In general, we believe it would be helpful if the EIS illustrated compliance with E.O.
11988 by presenting expected primary and secondary impacts and necessary mitigation
measures under a subsection of Chapter V analogous to the subsection titled "Flood-
Prone Areas" under the Environmentally Sensitive Areas section of Chapter III. Such
a treatment of E.O. 11988 issues would make the fact of compliance more explicit.
If you have any questions concerning these comments, please contact Joseph Gavin of
this office at FTS 597-9581.
Sincerely yours,
Walter P. Pierson
Director
Insurance and Mitigation
B-67
-------
APPENDIX C
Evaluation of Treatment Requirements
for Rock Creek
-------
EVALUATION OF TREATMENT REQUIREMENTS FOR ROCK CREEK
I. INTRODUCTION AND PURPOSE
The wastewater management scheme selected in the Final EIS for the
Gettysburg area consists of three sewage treatment plants. Among them,
the Cumberland STP and Gettysburg STP will be upgraded and expanded and
their effluents will be discharged directly into Rock Creek at the existing
outfall locations. A new Lake Heritage STP serving the Lake Heritage
residents will discharge into White Run which, in turn, enters Rock Creek.
The design of upgrading and expansion for these treatment facilities
was initially based on the effluent limits proposed by the Pennsylvania
Department of Environmental Resources (DER). The proposed stringent effluent
limits for the Rock Creek basin are considered advanced secondary treatment
level according to today's standards.
With the rising costs of building wastewater treatment facilities,
congressional budget and appropriations committees become more skeptical
about assumptions that treatment beyond secondary is either necessary or
worthwhile everywhere. As a result, EPA has been directed repeatedly by
the Congress to review all grants for advanced secondary treatment (AST)
and advanced waste treatment (AWT). The review process is outlined in the
revised PRM 79-7 which was published in the Federal Register (45 FR 41890,
June 20, 1980).
Two of the key elements in the review are water quality justifica-
tion and incremental cost analysis. This report provides information for
these two elements. The water quality justification requires the evaluation
of effluent limitations proposed by DER. That is, modeling of Rock Creek
is conducted to determine if the stream water quality will meet the stream
water quality standards while the DER proposed effluent limits are adopted.
Preliminary modeling results presented in the Draft EIS (EPA 1980) indicate
that the resulting stream water quality will exceed the stream water quality
standards. For example, the minimum dissolved oxygen level in Rock Creek
under 7-day 10-year low flow conditions will be 6 mg/1, a level higher than
the minimum 5 mg/1 required by DER for Rock Creek. It is suggested that
BODr and ammonia limits less stringent than the DER proposed limits be
applied while still meeting DER's stream standards. This comparison of
stream water quality is more pronounced for the smaller treatment facilities
such as Cumberland and Lake Heritage STP's. That is, even less stringent
limits can be applied to these smaller facilities.
The purpose of this study is to conduct a waste load allocation
and to derive less stringent effluent limits in terms of BOD^, ammonia,
total phosphorus, and total suspended solids for the three treatment plants.
It is expected that the calculated effluent limits (expected to be slightly
more stringent than secondary treatment) will serve as a guide for implementa-
tion of wastewater treatment requirements during the upcoming Step 2 (design)
of the Construction Grant Program.
C-l
-------
Computations will be conducted to determine the incremental cost for
treatment beyond the secondary level; that is, the cost difference in
treatment between the secondary level and the advanced secondary level pro-
posed by DER, as well as the difference between the secondary treatment and
the treatment level determined from waste load allocations. If the incre-
mental cost is higher than $3 million, the project will be reviewed more
intensively by EPA.
II. WATER QUALITY STANDARDS FOR ROCK CREEK
Water quality standards established for Rock Creek watershed by
DER are summarized in Table 1.
Table 1. Water Quality Standards for Rock Creek Watershed*
Parameter
Standard
PH
Dissolved Oxygen
Total Iron
Temperature
Ammonia Nitrogen
Dissolved Solids
Dissolved Phosphorus
Fecal Coliform
6.0 - 8.5
Minimum daily average 5.0 mg/1
Absolute minimum 4.0 mg/1
Below 1.5 mg/1
Not more than a 5° F rise above ambient
temperature or a maximum of 87 F,
whichever is less; not to be changed
by more than 2 F during any one-hour
period
1.5 mg N/1
Maximum monthly average 500 mg/1
Absolute maximum 750 mg/1
0.1 mg'P/1
Below 200 per 100 ml
* Rules and Regulations, Title 25 — Environmental Resources, Part 1.
Department of Environmental Resources Subpart C. Protection of Natural
Resources, Article II. Water Resources Chapter 93. Water Quality
Standards, Pennsylvania Bulletin, January 1980.
C-2
-------
The water quality constituents concerned in this study are dissolved
oxygen, ammonia nitrogen for toxicity reason, and total phosphorus.
Since total phosphorus standard for Rock Creek is not established by DER,
a level of 1.0 mg/1 total phosphorus in the stream (based on literature
values) was used to prevent significant algal growth.
III. PROPOSED EFFLUENT LIMITS/PRESENT EFFLUENT QUALITY
The proposed effluent limits for the Rock Creek basin are BOD
15 mg/1, total suspended solids 15 mg/1, ammonia nitrogen 3 mg/1 in summer
and 9 mg/1 in winter, and total phosphorus 1 mg/1. These effluent limits
are beyond the secondary treatment and close to the advanced treatment
level. The present effluent quality at the Gettysburg and Cumberland
STP's are summarized in Table 2.
Table 2. Effluent Quality* at Cumberland and Gettysburg STP
Total Suspended BOD,- Ammonia Total P
Solids (mg/1) (mg/1) (mg N/1) (mg P/l)
Cumberland 2.0 34.5 9.6 5.6
Gettysburg 5.0 58.5 12.0 6.5
*Water quality survey on August 8-9, 1979
The present concentrations of BOD,., ammonia and total phosphorus in the
effluent based on the 1979 survey exceed the proposed effluent limitations
proposed by the state.
IV. MODELING WATER QUALITY OF ROCK CREEK
A. Model Calibration/Verification
The BOD/DO model of Rock Creek was calibrated using the data collected
in the August 1979 extensive survey. The measured in-stream water quality
parameters, hydraulic geometry, and stream flows were incorporated into
the model. Measured effluent characteristics from the Cumberland STP and
Gettysburg STP were also included in model calibration analysis.
The results of this calibration analysis are presented In Figure 1.
Also shown in this figure are the BOD, and nitrogenous BOD loadings measured
at the Cumberland and Gettysburg STP's. A comparison of observed and
calculated BODc and nitrogenous BOD concentrations is also presented. In
general, the calculations match the data very well. Similar comparison is
demonstrated for nitrogenous BOD, the second stage of in-stream oxidation.
That is, nitrification in Rock Creek is delayed under low DO conditions
such as this one encountered in August 1979. The phase-lag of nitrification
process is substantiated by examining the distributions of nitrogenous BOD
and nitrate nitrogen in Rock Creek (Figure 2). Figure 2 shows that the peak
nitrate concentration is approximately at mile point 6.0 while the peak
ammonia concentration is at mile point 3.0, suggesting a phase-lag between
the carbonaceous BOD and nitrogenous BOD oxidation processes.
C-3
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Table 3 lists the key model parameters such as stream flow, depth,
velocity, and reaction coefficients used in the calibration analysis. For
additional information as to model segmentation and detailed computation
procedures, the Draft EIS appendix should be consulted.
Additional credibility for the model can be inferred from verifying
another set of data that was collected under different hydrologic and
loading conditions in Rock Creek. Thus, the August 1969 data set was used
to further calibrate the BOD/DO model. The results of this model calibra-
tion/verification exercise are presented in Figure 3 which shows again
favorable comparison between the model calculations and observations.
In order to further verify the model, another data set collected in
October 1973 was used. The stream discharge and temperature were
different than those observed in the August 1979 and August 1969 surveys.
Due to the high DO level in the stream, nitrification was assumed to begin
at the same time as the oxidation of carbonaceous BOD. The results of veri-
fication using the 1973 data (Figure 4) show good comparison between
calculations and observations. The above results have demonstrated that
the BOD/DO model of Rock Creek reproduces three different data sets very
well and, therefore, can be considered successfully verified.
A similar model was developed for total phosphorus in Rock Creek.
Figure 5 shows the results of model calibration using the August 1979
data set. A first-order decay rate of 0.15/day was determined from this
model calibration analysis by reproducing the observed phosphorus concentra-
tion profile in Rock Creek. Unfortunately, additional data set on phosophorus
is not available for further model verification.
C-6
-------
Table 3.
Model Parameters Related
August 1979 Conditions
to the
Segment
Mile
Flow
Depth
Velocity
No.
Point
(cfs)
(ft.)
(ft./sec
1
-1.0-0.0
1.2
0.40
0.08
2
0.0-1.7
2.4
0.80
0.12
3
1.7-3.0
3.6
0.90
0.14
4
3.0-4.0
4.2
1.00
0.13
5
4.0-5.0
4.6
1.10
0.10
6
5.0-6.0
4.6
1.20
0.10
7
6.0-6.7
7.1
1.30
0.16
8
6.7-8.0
8.6
1.30
0.19
9
8.0-9.0
8.6
1.40
0.19
10
9.0-9.5
8.6
1.40
0.19
11
9.5-11.0
9.4
1.50
0.21
+ Downstream from Cumberland STP
* At 20° C
BOD
Removal
Rate*
(1/day)
0.5
1.0
1.0
0.9
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Deoxy-
genation
Rate*
(1/day)
0.5
1.0
0.8
0.7
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Nitrification
Rate*
(1/day)
0.0
0.0
0.0
0.0
0.63
0.63
0.63
0.63
0.63
0.63
0.63
Cumulative
Time of
Travel
(Day)
0.86
1.41
1.89
2.49
3.08
3.36
3.77
4.09
4.25
4.69
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B. Model Application to Low Flow Conditions
The accepted design stream flow, to which the water quality criteria
as set forth will apply in Pennsylvania, is the actual or estimated lowest seven-
consecutive-day average flow that occurs once in ten years for a stream with
unregulated flow, or the estimated minimum flow for a stream with regulated
flows. That is, over a long period of time, the average time interval between
7-day low flow of this severity will be ten years. There is no stream flow gaug-
ing station in Rock Creek. The 7-day 10-year low flows along the stream were
estimated (EPA 1980) and are presented in Table 4 along the other model physi-
cal parameters.
Table 4. Model Physical Parameters Under 7-Day 10-Year Low Flow
Conditions.
Cumulated
Segment
Mile d
Flow
Depth
Velocity
Time of
No.
Point
(cfs)
.(ft)
(ft./sec.)
Travel (Day)
1
-1.0-0.0
0.5
0.2
0.05
—
2
0.0-1.7
i.oa
0.6
0.07
1.55
3
1.7-2.4
3.6b
0.7
0.18
1.79
4
2.4-3.0
3.6
0.8
0.12
2.10
5
3.0-4.0
3.9
0.9
0.13
2.57
6
4.0-5.0
4.1
1.0
0.10
3.16
7
5.0-6.0
4.1
X » x
0.14
3.61
8
6.0-6.7
4.8C
J- ~ J.
0.13
3.94
9
6.7-8.0
5.3
-L • -L
0.14
4.51
10
8.0-9.0
5.3
1 • X
0.15
4.95
11
9.0-9.5
5.3
J. • X
0.15
5.17
12
9.5-11.0
5.6
1.2
0.16
5.79
aincluding wastewater flow of 0.167 mgd from Cumberland STP
^including wastewater flow of 1.58 mgd from Gettysburg STP
°including 0.7 cfs of tributary flow from White Run and wastewater
flow from Lake Heritage STP
^downstream from Cumberland STP
The verified BOD/DO model of Rock Creek was used to calculate the
dissolved oxygen levels under the existing BOD,- and nitrogenous loading
rates (measured in August 1979) and the 7-day 10-year low flow conditions.
C-ll
-------
The results of the model calculation are shown in Figure 6. Rock Creek under
the existing loading conditions exhibits a minimum DO of 1 mg/1 immediately
downstream from the Gettysburg STP. Another low DO of 1.5 mg/1 is calculated
to occur about 3 miles downstream from the plant discharge as a result of stream
nitrification. Rock Creek then recovers and the DO level becomes above 5 mg/1
beyond mile point 6.0.
C. Dissolved Oxygen Resulting from PER Proposed Limits
The BOD/DO model was then used to calculate the dissolved oxygen levels
in Rock Creek under the assumption that the Cumberland STP, Gettysburg STP,
and Lake Heritage STP will comply with the DER proposed effluent limits:
TSS 15 mg/1, BODj. 15 mg/1, and NHo 3 mg/1 in summer months. The result of model
prediction is also presented in Figure 6 for comparison with the dissolved oxygen
levels under existing loading rates. The comparison shows that compliance
with the proposed DER limits will result in significant water quality improve-
ment by raising the dissolved oxygen levels in Rock Creek. The improvement over
the existing condition is so substantial that the minimum dissolved oxygen level,
6 mg/1, is higher than the minimum 5 mg/1 required by DER for Rock Creek.
The results suggest that less stringent effluent limits apply while still meeting
the minimum 5 mg/1 dissolved oxygen requirement..
D. Waste Load Allocation
A waste load allocations analysis was then conducted using the
BOD/DO model of Rock Creek to determine the minimum effluent requirements
(BOD,, and NHO for the three wastewater treatment facilities. The governing
factors considered in this analysis are: (1) minimum stream dissolved oxygen
level 5 mg/1 and (2) maximum BOD,, level in the effluent 30 mg/1. The second
factor mandates a secondary treatment level as a minimum for all facilities.
The results of waste load allocations are summarized in Figure 7. The
minimum dissolved oxygen level in Rock Creek is about 5.2 mg/1 downstream
from the Gettysburg STP with effluent limits of BOD^ 25 mg/1 and NH^ 3 mg/1.
Secondary treatment level with BOD^ of 30 mg/1 is acceptable for Cumberland
and Lake Heritage STP's. Ammonia nitrogen requirements at Cumberland Lake
Heritage STP's can be as high as 15 mg/1. This NH level in the effluent
requires no nitrification at the plants under the 7-day 10-year low flow con-
dition. The dissolved oxygen levels in the effluent varies from 5 mg/1 to
7 mg/1 in the modeling analysis. No significant difference in stream dissolved
oxygen levels is predicted by the model. As a result, dissolved oxygen
concentration in the effluents is not an important factor as compared with
BOD^ and NH^.
E. Toxicity of Ammonia Nitrogen
The state DER requires a maximum level of 1.5 mg/1 ammonia nitrogen
in Rock Creek for toxicity reasons. The calculated ammonia nitrogen limits
in the effluents were reviewed to determine if they meet the toxicity standard.
The calculated ammonia nitrogen concentrations in Rock Creek are shown in
Figure 8. The first curve in Figure 8 is associated with the ammonia limits
derived in the preceding section. It is seen that the derived limits for
Cumberland and Gettysburg STP's are too high for toxicity concern in the
C-12
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stream. Subsequently, a waste load allocation for ammonia nitrogen was conducted
and the results are represented by curve 2 in Figure 8. In order to maintain
the ammonia nitrogen level below 1.5 mg/1 in the stream, these limitations
are required: 3 mg/1 at Cumberland, 2 mg/1 at Gettysburg, and 15 mg/1 at Lake
Heritage. These results indicate that nitrification process is required at
Cumberland and Gettysburg STP's. Although nitrification is not required at
Lake Heritage STP based on the model calculation, high ammonia levels can be
found in White Run below the outfall but before the junction of White Run with
Rock Creek. At the present time, however, there is no DER requirement on
ammonia nitrogen levels in White Run.
F. Seasonal Effluent Limitations
Pennsylvania has placed limitation for ammonia on the Gettysburg
facility. From June 1 through October 31, the plants are required to meet
a limitation of 3 mg/1 of ammonia; the remainder of the year, the facilities
should meet an ammonia limit of 9 mg/1. The non-summer low flow for Rock
Creek has been estimated as 11 cfs at the Gettysburg STP with a critical
temperature of 15 C. For the temperature of 15 C and a pH value of 7.5,
the EPA Quality Criteria for Water indicates that an in-stream NH„ level of
2.3 mg/1 would maintain a condition that is not toxic to fish. DER's limita-
tion of 9 mg/1 NH- will result in a stream concentration, for the above
conditions, of 2.4 mg/1 NH-. As can be seen, this will maintain concentra-
tions as suggested by EPA Criteria.
G. Total Phosphorus Limitation
The state DER has proposed a total phosphorus effluent limit of
1.0 mg/1 for the Rock Creek basin. The calculated phosphorus model was used
to predict the resulting phosphorus level in Rock Creek under the 7-day 10-year
low flow condition. The results are shown in Figure 9 (see curve #2). The
maximum total phosphorus concentration in Rock Creek is about 0.8 mg/1 immediately
downstream from the Gettysburg STP.
There is no total phosphorus standard established for Rock Creek at
the present time for comparison with the above model calculations. However,
literature has presented free-flowing stream situations where nuisance algae
blooms have occurred when phosphorus concentrations are in the 0.1 mg/1 to
0.6 mg/1 range. Additional research has indicated limiting phosphorus
concentrations to range from 0.1 mg/1 to 1.0 mg/1, with drastic reduction in
growth rates below 1.0 mg/1. The above model results illustrate that the pro-
posed 1.0 mg/1 phosphorus effluent limitation would yield phosphorus levels
below 1.0 mg/1 in the stream.
Figure 9 also indicates that higher phosophorus levels in the
effluents from both Cumberland and Lake Heritage STP's are applicable.
Therefore, the phosphorus model of Rock Creek was used to determine the
maximum phosphorus concentrations that are allowed in the effluents while
maintaining the stream phosphorus levels below 1.0 mg/1. The results are
also presented in Figure 9 (see curve #1). The effluent phosphorus limits
determined are 3.0 mg/1, 1.0 mg/1 and 7.0 mg/1 for Cumberland, Gettysburg,
and Lake Heritage STP's, respectively. It is believed that these limits
would be adequate to prevent significant plant growth problem in Rock Creek.
C-16
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C-17
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V. RECOMMENDED EFFLUENT LIMITS
Table 5 summarizes the effluent limits for Cumberland, Gettysburg,
and Lake Heritage STP's derived in the waste load allocations for Rock Creek.
Table 5. Effluent Limits Based on Waste Load Allocations
STP
Flow
(mgd)
bod5
(mg/1)
NH
(mg/1)
TP
(mg/1)
DO
(mg/1)
Cumberland
0.17
30
3.0
3.0
5.0
Gettysburg
1.58
25
2.0
1.0
5.0
Lake Heritage
0.14
30
15.0
7.0
5.0
It is recommended that cautions be exercised to use these limits for
the following reasons. For example, nitrification required at Cumberland STP
to produce effluents with NH_ below 3 mg/1 will have benefit for BOD,, oxidation
as well, so that the effluent BOD^ will be lower than 30 mg/1. Similar results
will be obtained at the Gettysburg STP also. Therefore, the effluent limits in
Table 5 represent the worst case scenario and can only be used as a guide for
design.
The actual effluent quality is expected to exceed that (Table 5) to
some extent. As a result, for Cumberland STP, a secondary treatment with
nitrification is recommended. Phosphorus removal is also required.
Gettysburg STP will need secondary treatment with nitrification.
Phosphorus removal to produce effluents with total phosphorus concentration
no more than 1.0 mg/1 is recommended.
Lake Heritage, with secondary treatment, will meet the water quality
requirements for Rock Creek. Nitrification and phosphorus are not needed for
Rock Creek's concern. However, high ammonia and phosphorus levels will exist
in the immediate vicinity of the outfall on White Run.
Although no quantitative analysis of effluent limits for total suspended
solids was conducted, it is believed that based on the above analysis, secondary
treatment should yield effluents with acceptable total suspended solids
concentrations.
C-18
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VI.
PROJECT COST
The capital costs and annual operation and maintenance costs for
sewage treatment of the Cumberland, Gettysburg, and Lake Heritage STP's
based on the DER proposed effluent limits are summarized as follows:
Cumberland
STP
Gettysburg
STP
Lake Heritage
STP
Capital ($ x 10 )
0 & M ($ x 103)
417.0
46.0
3,440.0
264.0
301.0
38.0
The newly derived effluent limits shown in Table 5 are not expected to
substantially reduce the capital and O&M costs for Cumberland and Gettys-
burg because both facilities will still require nitrification process (mainly
to satisfy the stream ammonia toxicity standard). Secondly, both facilities
will still have phosphorus removal process.
Any reduction in capital and O&M cost will probably come from the
Lake Heritage STP because the modeling result suggests that nitrification
and phosphorus removal are not necessary. It is difficult, however, to
estimate the accurate cost saving at this point of time simply because the
exact treatment scheme has not been finalized. Lake Heritage has the option
to purchase the package AWT plant from the Washington Suburban Sanitary Com-
mission or to construct a new oxidation ditch plant. Both options have the
capability of nitrification.
Finally, the $3 million incremental cost will not be exceeded in
either case (DER proposed effluent limits and newly derived effluent limits)
because the total capital cost for Gettysburg STP is only $3.4 million.
Capital costs for Cumberland STP and Lake Heritage STP are much below
$1 million to begin with. Thus, the project is not expected to undergo
AST/AWT review.
The project costs presented are based on rough estimates of the
conceptual design for the treatment facilities. It is recommended, however,
that a value engineering analysis be conducted for next level of cost
estimates during the Step 2 design.
C-19
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APPENDIX D
DEIS Appendix G-7 Addendum
Survey of Aesthetic Resources
of the Gettysburg National
Historic District, Gettysburg,
Pennsylvania
-------
The aesthetic inventory was published originally as Appendix G-7
in the DEIS. As the result of questions and comments concerning this
inventory, additional field work was conducted, particularly in the
Barlow Knoll, Peace Memorial, and East Cavalry Battlefield areas. The
following photographs modify and expand the inventory of 28 stations
as presented in the DEIS. Figure III-2 of the Final EIS (revised DEIS
Figure III-ll) has been updated to reflect this new information.
D-l
-------
View north from entrance to Benner Hill, Gettysburg National Military Park, April 1981. C, c.
-------
Station 10.
D—3
-------
. - r
\j
1. View northwest from Benner Hill, Gettysburg National Military Park. Gettysburg Wastewater Treatment
Plant is in wooded area at extreme left of photograph. April 1981. C,c.
-------
Station 12.
D-5
-------
1. Panoramic view southeast — southwest 180° from Barlow Knoll. Gettysburg National Military Park,
April 1981. F & D, C & i.
w
-------
2. View southwest - northwest from Barlow Knoll, Gettysburg National Military Park, April 1981. D & A, c & i.
-------
3. View northwest - northeast from Barlow Knoll, Gettysburg National Military Park, April 1981. B,C
-------
4. View northeast - southeast, Barlow Knoll, Gettysburg National Military Park, April 1981. C & B,c.
-------
5. Degraded view southeast toward King's Supermarket from Barlow Knoll,
Gettysburg National Military Park, April 1981. D,i.
D-10
-------
Dense stand of trees which screens view north from Barlow
Gettysburg National Military Park, April 1981. A,C.
D-ll
-------
Station 29.
D-12
-------
View west - south from Oak Ridge Observation Tower, Gettysburg National
Military Park, April 1981. Developable land is in the left midground.
The Ford agency is visible on the left; Gettysburg Tower is in right
farground. B,C, & D; c & i.
D-13
-------
View northeast - northwest from Oak Ridge Tower, Gettysburg National Military Park, April 1981.
A,B,C, & D;c.
-------
Station 30.
D-I5
-------
View northeast - southeast from entrance to Peace Memorial, Gettysburg
National Military Park, April 1981. B & C & D; c & i.
D—16
-------
Station 31.
D-17
-------
1. View southwest from entrance to East Cavalry Battlefield Site north of PA 116, Gettysburg, Pennsylvania,
April 1981. B & C, c.
-------
Station 32.
D-19
-------
View south from General Custer's Memorial, East Cavalry Battlefield Site, Gettysburg, Pennsylvania,
April 1981. Figure III & II, Station 32, B, c.
-------
Station 33.
D-21
-------
View southwest from Station 33. Developable land at Lake Heritage and
north of Route 116, would not be visible from this location. East
Cavalry Battlefield Site, Gettysburg, Pennsylvania, April 1981. B, c.
D-22
-------
Station 34.
D-23
-------
1.
View west from PA 116 east of the entrance to the East Cavalry Battlefield Site, Gettysburg,
Pennsylvania. April 1981. B & C, c.
-------
Station 35.
D-25
-------
1. View south from south of Route PA 116 east of Plum Run toward Lake Heritage. Gettysburg, Pennsylvania,
April 1981. A, C.
-------
View southwest toward Lake Heritage from south of PA 116. Gettysburg,
Pennsylvania, April 1981. C, c.
D-27
-------
3. View west southwest from south of PA 116, at junction of Lake Heritage
and Plum Run. Gettysburg, Pennsylvania, April 1981. C,c.
D-28
-------
Station 36.
D-29
-------
1. View north from Culp's Hill. Gettysburg Wastewater Treatment Plant is
in wooded section in the center of the photograph. House on Benner
Hill is on hilltop on the right side of the photograph. Gettysburg,
Pennsylvania, April 1981. A, D & C; c & i.
D-30
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APPENDIX E
DEIS Appendix G-8
-------
* A Plan to Preserve the Historic
Resources of the Gettysburg Area of
the Commonwealth of Pennsylvania
A Report Prepared by*the Advisory
Council on Historic Preservation *
E-l
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Table of Contents
Introduction I
What Can Be done: A New Preservation Program for the Gettysburg Area 1
Appendix
Part I The Federal Properties 17
Part II History and Development of Adams County, the 22
Borough of Gettysburg, and Cumberland Township
Part III Planning in the Gettysburg Area 28
Bibliography 38
Acknowledgment 40
-ft US. GOVERNMENT PRINTING OFFICE : 1977 0-247-9*0
For sale by the Superintendent of Documents, U.S. Government Printing Office
Washington, D.C. 20402
Stock No. 024-000-00838-0
E-2
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Introduction
Established in 1917 to honor writings that
contribute to an understanding and appreciation
of American principles and ideals, the Pulitzer
Prize for Fiction is one of our most coveted
literary awards. In 1975, the winner was The
Killer Angels, a novel written by Michael
Shaara, who described his work simply as "the
story of the Battle of Gettysburg told from the
viewpoint of Robert E. Lee and James
Longstreet and some of the other men who
fought there." It was, of course, much more than
that, but the point is that Gettysburg continues
to be a subject able to stir the minds of our best
young writers, as well as historians, teachers,
school children, and the millions who annually
visit the site of the great battle. Why? Because
the events that occurred there shaped our
national life, and the lessons learned there are
lessons we need to remember.
It was for these reasons in 1896 that the
United States Supreme Court upheld the right of
the Secretary of War to condemn a part of the
battlefield in private ownership for the purpose
of protecting it for the use and inspiration of all
Americans. Speaking for the court, Justice
Rufus Peckham declared that the taking of
property for this purpose "touches the heart, and
comes home to the imagination of every citizen,
and greatly tends to enhance his love and
respect for those institutions for which these
heroic sacrifices were made." Peckham pointed
out that this love and respect were essential to
the perpetuation of the Nation: "The greater the
love of the citizen for the institutions of his
country the greater is the dependence properly
to be placed upon him for their defense in time
of necessity, and it is to such men that the
country must look for its safety." Thus, it was at
Gettysburg that the concept of the right of
condemnation of private property for historical
purposes was first tested and not found wanting.
What then were the events that occurred there
and the lessons learned? Why is Gettysburg a
very special place? One reason Gettysburg is a
very special place is because of the many who
died there. The Battle of Gettysburg was a
terrible, tragic event in our history, and yet,
perhaps ironically, it remains a source of
national strength and inspiration. Described at
the time as "an unremarkable Pennsylvania
market town," Gettysburg became an
uncommon ground on July 1,2, and 3,1863,
when more men died in the battle fought there
than in any other battle fought before or since on
American soil. In 1881, Jefferson Davis called
it, "the most eventful struggle of the war," and
time has proven him correct.
The Union victory ended the last Confederate
invasion of the North and marked the beginning
of a gradual decline in Southern military power.
Distinguished Civil War historian Bruce Catton
sees the battle as the great hinge of the conflict,
"the turning point where it began to swing in a
different direction," and labels the site as "the
greatest of our battlefields."
Abraham Lincoln made fast its greatness
when he spoke at the dedication of the Soldiers'
National Cemetery on November 19,1863.
Reminding his listeners that the American
people had brough forth "a new nation,
conceived in Liberty, and dedicated to the
proposition that all men were created equal," he
likened the Great War to a testing, a testing to
determine whether that nation and the ideals it
embodied could long endure. Death was the
ultimate sacrifice, and the terrible rendering at
Gettysburg was a price paid in pursuit of that
dream. He asked that his countrymen stand firm
in future accountings sure to come in order to
give meaning to the loss of life at Gettysburg and
to ensure that "government of the people, by the
people, for the people, shall not perish from the
earth." Thus Lincoln's statement gave larger
meaning to the conflict, and Gettysburg became
one of our most poignant and powerful symbols
for democracy.
It is proper and fitting that another man who
knew much about war and diplomacy chose to
make his home at Gettysburg. Dwight D.
Eisenhower bought a farm there in 1950, a place
much in the news whether as a weekend retreat,
a refuge in time of illness, or the site of visits
ftom such foreign dignitaries as Premier
Khrushchev, Chancellor Adenauer, President
DeGaulle, or Prime Minister Nehru. Following
his retirement in 1951, President Eisenhower
took special interest in reclaiming the land and
preserving the scene where Longstreet's Corps
formed its battle lines on the second of those
fateful days in July, 1863.
Gettysburg National Military Park,
Gettysburg National Cemetery, and Eisenhower
National Historic Site are three of the most
important historical parks under Federal
control. Indeed, two of them rank among the
handful of our greatest historic properties
anywhere. But that is not all; there is more at
Gettysburg. Much of the historic town remains
and has been designated a historic district by the
Commonwealth of Pennsylvania and protected
by borough zoning. One hundred twelve of the
336 buildings in Gettysburg at the time of the
battle are still standing. One of the most
important resources is the beauty of the natural
E-3
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landscape in Adams County, and, in many cases,
views from prime locations on the battlefield are
traditional ones, quiet agricultural scenes
unimpeded by instrusions or developments that
are not compatible with the historic setting.
Rich in history, rich in historical resources,
rich in natural beauty, Gettysburg is a very
special place. But like very special places, it
attracts and attraction often means
development, and sometimes development can
mean a loss of history, a loss of historical
resources, and a loss of natural beauty.
Development pressures at Gettysburg are
evident. While the borough has little room left
for expansion, adjacent Cumberland Township
is beginning to change from an agricultural
region to a suburb and is ripe for speculative
ventures generated by increased tourism.
Significant intrusions like the privately owned
National Gettysburg Battlefield Tower are
already there, and unless something is done in
the future, the Gettysburg area will lose its sense
of place, and the things that make it very special
will disappear—diminished, eroded, and erased
by density, modernity, and sameness.
There is another thing about Gettysburg. It
has been special so long that it has been taken
for granted. While great new natural and
historical parks have been added to the National
Park System in the past decade, not enough has
been done at Gettysburg, which exceeds most of
them in importance and meaning. The National
Park Service is burdened by limitations imposed
upon it by an antiquated preservation plan
conceived in 1895 when there were no
development pressures and visions of a 307-foot
tower staring down on the place where Lincoln
stood could only be attributed to a heavy meal
before retiring. Adams County has no interest in
zoning, and Steinwehr Avenue at the foot of
Cemetery Hill is becoming one great fast food
complex, a monument to the importance of the
hamburger in American life.
And yet there are vital signs in Gettysburg. It
has not forgotten its past, In 1972 the borough
passed a historic zoning ordinance, and a sign
ordinance whose restrictive provisions become
effective in November, 1978; Cumberland
Township is considering the adoption of a land
use plan, hopefully to be followed by zoning; a
Community Relations Committee, formed to
promote cooperation between the National Park
Service and the community, recently adopted
articles of organization; Historic Gettysburg-
Adams County, Inc., a private non-profit
organization founded in 1975, is developing a
campaign to beautify the town under a 13-year
plan; the National Park Service promises to
complete its long-awaited master plan for the
military park and cemetery; and merchants in
the borough are beginning to renovate and
restore historic commercial buildings.
Perhaps the single, most important factor in
stimulating a renewed interest in Gettysburg, the
catalytic agent that stirred the collective
conscience and drew attention to an area never
forgotten but recently ignored, was the
construction of the National Gettysburg
Battlefield Tower. The tower is also the reason
that the Advisory Council on Historic
Preservation initially became involved in
preservation problems at Gettysburg.
The tower controversy began on August 4,
1970, when Mr. Thomas R. Ottenstein of Chevy
Chase, Maryland, called upon Mr. George B.
Hartzog, Director of the National Park Service,
for the purpose of informing him of the intention
of a newly organized corporation to build a 300-
foot tower near the Jennie Wade House on
Cemetery Hill. Characterizing the tower as a
monstrosity, Hartzog expressed chagrin that the
Borough of Gettysburg had granted a
construction permit. Subsequently, Ottenstein
chose another location within the borough in the
subdivision of Colt Park, a short distance north
of the park boundary and the field of Pickett's
Charge, and began some preliminary work on
the site. Much to the surprise of many, a few
months later, on July 2, 1971, the National Park
Service entered into an "Agreement and Land
Exchange" with the National Gettysburg
Battlefield Tower and Mr. Ottenstein. The
agreement allowed the developer a 22-foot
right-of-way across park lands to another
privately owned site behind the Stonehenge
Motel, where the tower was now to be
constructed. In return the corporation agreed to
donate five percent of its "taxable income" to a
non-profit foundation established for charitable
and historic preservation purposes and to
convey the Colt Park site to the National Park
Service. In subsequent statements, Service
spokesman observed that the agreement did not
constitute approval of the tower but was made to
minimize its adverse effects, and justified the
action by pointing to a lack of local zoning or
any other practical means of controlling
development of that kind. However, many
believed that the agreement was ill-conceived
and that the treatment prescribed by the
National Park Service was nearly as bad as the
disease. While a tower at the Stonehenge site
might be less intrusive, it would still have
tremendous visual impact on the battlefield and
E-4
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surrounding area. The site was approximately
1,200 feet from where President Lincoln
delivered the Gettysburg Address and
approximately 2,500 feet from the High Water
Mark of the Confederacy, the pivotal point in
the battle.
Eighteen days after the signing of the
agreement, the Commonwealth of Pennsylvania
sued the National Gettysburg Battlefield Tower
and Mr. Ottenstein in the Court of Common
Pleas of Adams County to permanently enjoin
construction of any tower near the military park,
the national cemetery, and the Eisenhower
farm. The court denied the injunction stating
that the Commonwealth had failed to show clear
and convincing proof that the natural historic,
scenic, and esthetic values of the Gettysburg
area would be irreparably harmed by the
erection of the proposed tower, citing the
participation of the National Park Service in the
agreement as evidence that such values would
not be harmed. The Commonwealth appealed
the case.
On January 24,1972, while the appeal was
pending, the Department of the Interior, in
accordance with Section 106 of the National
Historic Preservation Act of 1966, requested
the comments of the Advisory Council on
Historic Preservation on the agreement,
explaining the lack of previous referral as an
oversight.
The Council initially considered the matter of
the Gettysburg tower at its May 3-4, 1972,
meeting. The Council found that a tower at any
location in the vicinity of Gettysburg National
Military Park, Gettysburg National Cemetery,
and the Eisenhower National Historic Site
would have an adverse effect upon those
resources. In its comments, the Council stated:
"The character and height of the proposed
tower is out of keeping with the historic
structures and monuments of the battlefield, the
farming countryside... and the rural townscape
of the Borough of Gettysburg." Because of the
adverse visual impacts of the tower, the Council
looked "unfavorably" upon the consequences of
the agreement negotiated by the National Park
Service and recommended that steps be taken to
explore appropriate legal remedies to stop
construction at the Stonehenge site and any site
proposed in the future. The Council further
recommended that the National Park Service
make clear its position that the agreement with
the National Gettysburg Battlefield Tower and
Mr. Ottenstein was iii no sense an approval of
the tower and that it do everything it could to
assist the Commonwealth of Pennsylvania in its
legal action at Gettysburg. Finally, the Council
concluded that the Secretary of the Interior
should have the means to control such
undesirable development as this in the vicinity
of all historical areas of the National Park
System and recommended that the Department
study ways of providing adequate protection to
these areas.
As a result of Council comments, the
Department of the Interior assisted the
Commonwealth in its suit. The Commonwealth,
however, lost its appeal in April, 1973.
Following the decision, the Ctommonwealth
brought suit in Federal court against the
Secretary of the Interior, contending that an
environmental impact statement should have
been prepared on the agreement. The court
ruled that the agreement did not constitute a
major Federal action within the meaning of the
National Environmental Policy Act and,
therefore, did not require an environmental
impact statement. The tower was completed and
opened for business on July 29, 1974. A single
picket paraded in protest.
As previously mentioned, much has been
accomplished since that time. One can only
surmise that the attention, the drama, the heated
reaction and even the bitterness served a useful
purpose. Deepened awareness, renewed pride in
what remains, and, perhaps, a sense of guilt have
caused a new interest at Gettysburg on the part
of the citizenry, the borough, Cumberland
Township, the State, and the Federal
Government.
On May 24,1976, Assistant Secretary of the
Interior Nathaniel P. Reed sent a letter to the
Executive Director of the Council informing
him that the National Park Service was in the
process of completing its legal responsibilities
imposed by the "Agreement and Land
Exchange"; that is, it was conveying an
unrestricted vehicle and pedestrial right-of-way
to Mr. Ottenstein, While being advised that the
agreement was binding and must be effected,
Mr. Reed stated that the Department continued
to remain strongly opposed to the tower.
Finally, he invited the Council to join with the
National Park Service to consider alternatives
that could be available "to avoid this type of
compromise decision in the future."
In response to the invitation, the Council
went to Gettysburg on August 5 as a part of its
regular summer meeting. After hearing from the
National Park Service, the State Historic
Preservation Officer, and a number of local
officials and representatives of community
organizations, the Council instructed its staff to
E-5
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prepare a report on what might be done at
Gettysburg to protect and enhance the historic
resources that are so abundant there, with an
emphasis on creative and innovative solutions to
critical problems. This report is a response to
that instruction.
In the pages that follow, we suggest ways in
which the objectives of historic preservation can
be met. In the appendix, the reader will find an
analysis of the historic resources of the
Gettysburg area; a discussion of past effort,
either successful or unsuccessful, to deal with
threatened impairments; and a description of the
authorities of the various jurisdictions and how
they have used or not used them to protect and
enhance historic properties. While the section
"What Can Be Done: A New Preservation
Program for the Gettysburg Area" is intended to
stand alone,the papers in the Appendix more
fully outline the basis for recommendations.
Now is the time to take another step forward
at Gettysburg. The report suggests how it might
be done. Perhaps Gettysburg will again be a
place where we can learn new lessons and
reaffirm three of America's traditional
characteristics: those of optimism, pragmatism,
and voluntary cooperation. We hope so, for
Gettysburg is a very special place.
E-6
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What Can be Done:
A New Preservation Program
for the Gettysburg Area
Many opportunities exist for developing a
stronger preservation program for the
Gettysburg area, and, fortunately, there are a
variety of ways in which preservation can be
accomplished or at least fostered. Encouraged
by the Commonwealth of Pennsylvania, actions
by the Borough of Gettysburg, the planning
effort of Cumberland Township, and the
educational program of Historic Gettysburg-
Adams County, Inc., have all contributed to a
new sense of awareness in the locality. Recent
Federal legislation provides new incentives for
the jurisdictions and private citizens to
participate in a broadened preservation
program, and there are other actions that the
Federal Government can take to preserve and
encourage the preservation of the historic
resources of the region and to protect for the
American People the Federal investment in the
battlefield, cemetery, and farm.
The following pages describe the things that
can be done by all parties involved—by citizens,
community organizations, the borough, the
townships, the State, the Department of the
Interior, other Federal agencies, and the
Congress of the United States. In some cases,
several jurisdictions have the ability to achieve
the desired goal, and if one does not act, another
can exercise its authority to accomplish a
particular objective. In cases of this kind, it is
hoped that local governmental entities will be
the first to act, avoiding the consideration of the
problem by other jurisdictions. Local
governmental entities will be better able to act if
they have a professional planning capability.
None have this except Adams County, and it is
recommended that other jurisdictions secure full
time professional help as soon as possible.
A. A Key: The Highway System
Many have compared the highway system at
Gettysburg to a wheel, imagining roads as
spokes and the town square as the hub. Major
highways that meet in the center of town are
U.S. 30 to York, Business U.S. 15 to Harrisburg
and Washington, U.S. 140to Baltimore,
Pennsylvania 116 to Hanover, and Pennsylvania
134 to Biglerville. Because of this circumstance,
major congestion occurs in the borough at and
near the town square and at several key
intersections. Worst congestion occurs on
weekends when visitation to the military park is
heaviest. Unfortunately, this coincides with the
peak of local shopping. Consequently, the
highway system works against both the park,
impeding visitation, and the town, making
purchasing more difficult and thereby creating
pressures to develop shopping centers in
suburban areas. Besides congestion, the noise,
fumes, and heavy signing detract appreciably
from the atmosphere of the historic urban
center, and movement of commerce away from
downtown will not only lead to a deterioration
of the core but may result in further intrusions
near Federal areas.
A bypass to U.S. 30 has long been
recommended as a way of removing congestion
from the borough and making it possible for the
National Park Service to put into effect its plans
for a new visitor contact and orientation center
north of Gettysburg. The proposed facility will
enable the National Park Service to interpret
the Battle of Gettysburg in better chronological
sequence and attract new commercial
development to a more suitable area, in terms of
visual impact upon the community's prime
historic resources. The estimated cost of the
bypass at the present time is between 25 and 30
million dollars.
Because 30 is a U.S. Highway, the Federal
government will fund 70 percent of the cost of
the bypass, leaving the matching share at
between 9 and 7.5 million. The Federal
Highway Administration has already approved
the project in concept, and an environmental
impact statement was prepared in 1971.
However, Adams County is unable to raise the
matching portion, having been allotted only
about $8 million for the next 12 years by the
Pennsylvania Department of Transportation,
which sets its priorities based on traffic volume.
The current allotment must go to keep present
roads maintained and make necessary
improvements on existing highways.
Because U.S. Bypass 30 is crucial to the
development of a new preservation plan, new
ways must be found to permit its construction,
and the only practical solution appears to be
100 percent Federal funding. One hundred
percent Federal funding might be accomplished
in one of two ways. Because 3 million visitors
visit Gettysburg National Military Park and the
National Cemetery, and because visitation will
increase at a rate greater than normal when the
Eisenhower National Historic Site is opened to
the public in future years, the National Park
Service could seek appropriations from the
Congress to make up the deficit. Such an
appropriation request can be justified in view of
the fact that congestion is substantially due to
visitor vehicular traffic and that park land has
not been taxable by the local jurisdictions. With
respect to the latter, one might view Federal
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funding of the matching share as partial
compensation to the State and municipalities for
tax losses over many decades.
It should be pointed out that 100 percent
Federal funding of highways is not without
precedent. In fact, Section 141 oft he Federal
Aid Highway Act of May 5, 1976 (Public Law
94-280) provides for a program to accelerate
highway projects by 100 percent funding when
there has been an impact due to a Federal
installation. One of the reasons for the provision
in the legislation was to permit the construction
of a U.S. Bypass 30 at Everett, Pennsylvania,
where the construction of Raystown Dam by the
U.S. Corps of Engineers resulted in traffic
congestion. The second possibility, then, would
be to utilize some of the monies appropriated for
the purposes of Section 141 to construct the
bypass at Gettysburg. During the present fiscal
year, 10 million dollars are available for
accelerated projects. (See Public Law 94-387
"Project Acceleration Demonstration
Program.")
Controls along the periphery of Bypass 30 will
be essential in order to ensure compatible
development.
B. A Vicious Circle;
Changing Economic Motivators
The Federal presence is a major factor in the
economic life of the Borough of Gettysburg,
Cumberland Township, and Adams County. As
Federal properties of outstanding historical
significance, Gettysburg National Military Park
and Gettysburg National Cemetery draw
millions of visitors to the area, 1.5 million in
1974, 2.3 million in 1975, and a probable 3.1
million in 1976. A study in 1970 indicated that
tourists pumped between 15 and 20 million
dollars into the local economy, and figures show
that the National Park Service contributes more
than one million in direct spending each year.
In the past, Federal properties have not
contributed to the tax base of the small local
jurisdictions with the result that they have been
burdened with the task of providing, willingly or
not, many of the services that millions of visitors
require. For example, visitation has had a
significant impact upon water, sewer, and road
systems. To benefit from tourism, the township
enacted an amusement tax, which brings in half
of its revenues, and has been receptive to
developments that will yield more income,
many of which are visually intrusive and
adversely affect the historic resources. To
combat intrusive developments near Federal
properties, the National Park Service, in some
cases, has acquired these properties. However,
acquisition has been distasteful to the county
because it depends on a real estate tax for much
of its income and to the township because of its
lossofthe important amusement tax.
1. Payment in Lieu of Taxes
New legislation, signed by the President on
October 20, 1976, recognizes that communities
have had to bear additional costs because of the
presence of large Federal properties in the area.
To compensate local governments for this
burden, the Payment in Lieu of Taxes Act
(Public Law 94-565) provides for the annual
return of 75 cents an acre on land owned by the
Federal Government on a permanent basis. In
addition, county taxing authorities—the county,
the township, and the school district—will share
in one percent of market value of land acquired
by the National Park Service since January 1,
1971, at an assessed value on that date.
According to a recent news release, Adams
County taxing authorities may receive as much
as $72,992 per year when the Congress funds the
program.
Prior to the passage of the Payment in Lieu of
Taxes Act, the National Park Service at
Gettysburg had taken steps to make some visitor
generated revenues available to the
municipalities by turning over the operation of
its "Electric Map" to the Eastern National Parks
and Monuments Association, a private
cooperating association whose income from the
map is subject to the township amusement tax.
As a further step, the National Park Service
should consider doing the same thing with the
operation of the Cyclorama program.
2. Entitlement for the Community
Development Program
There are other ways of reducing economic
pressures that obstruct or impede the
preservat ion of historic resources in the
Gettysburg area. In order to correct past
inequities and stimulate new programs, one step
that could be taken would be to qualify the
Borough of Gettysburg as a "metropolitan city"
under the Housing and Community
Development Act of August 22,1974 (Public
Law 93-383). This legislation makes annual
grants available to these cities for a wide variety
of purposes including acquisition of certain
kinds of real property, public works programs,
community services necessary to achieve
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community development objectives, the
improvement of public facilities, and historic
preservation activities. Grant monies can also
be used as a matching share for other Federal
programs requiring local contributions.
In order to qualify, a city must have a
population of 50,000 or more. The population
of the Borough of Gettysburg in 1970 was 7,275;
however, millions of tourists visit Gettysburg
National Military Park each year, creating
demands and pressures similar to those found in
much larger communities. Annual community
development grants would permit the borough
to deal with these demands and pressures in an
orderly fashion and to implement a city
beautification and historic preservation program
proposed by Historic Gettysburg-Adams
County, Inc., which includes building
restoration, burying of overhead utilities, and
installation of period street lighting and street
furniture. The Congress is aware of some
inequities in the criteria for determining eligible
cities, and before the close of the last session
held hearings to gather information to assist it in
considering amendments to the legislation,
which will be considered for renewal next year.
One way for the Borough of Gettysburg to
qualify as a metropolitan city would be for the
Congress to amend Section 102(a) (4) of the
1974 Act to give weight to visitation resulting
from the presence of Federal properties listed in
the National Register of Historic Places. For
example, if Gettysburg were able to count the
3.1 million visitors to Gettysburg National
Military Park at a rate of 25 to one, it would
easily qualify.
3. Federal Tax Incentives
and Disincentives
The new Tax Reform Act of 1976, signed into
law on October 4, will also contribute to the
redirection of economic pressures so that they
will favor rather than discourage preservation.
Section 2124, entitled "Tax Incentives to
Encourage the Preservation of Historic
Structures," contains five provisions that should
have substantial impact in the Gettysburg area.
These provisions are applicable to historic
properties individually listed or included in
historic districts that are listed in the National
Register of Historic Places. The five provisions
are:
a. Amortization of Rehabilitation Expenditures,
Section 2124(a) A new part, Section 191,
"Amortization of Certain Rehabilitation
Expenditures for Certified Historic Structures,"
was added to Part VI of subchapter B of Chapter
1 of the tax code relating to itemized
deductions. It provides that a taxpayer may
amortize over a 60-month period any capital
expenditure incurred in a certified
rehabilitation of a certified historic structure, in
lieu of depreciation deductions otherwise
allowable.
The law defines certified historic structure as
a building or structure which can be depreciated
as provided in Section 167ofthe tax code (i.e.,
the property must have some commercial
characteristics; residential property may qualify
if it is rented), and which is listed in the National
Register; located in a Registered Historic
District and is certified by the Secretary of the
Interior as being of historic significance to the
district; or located in a historic district
designated under a statute of the appropriate
State or local government, if the statute is
certified by the Secretary of Interior as
containing criteria that will substantially
achieve the purpose of preserving and
rehabilitating buildings of historic significance
to the district.
The law defines certified rehabilitation as any
rehabilitation of a certified historic structure
that the Secretary of the Interior has certified as
being consistent with the historic character of
the property or the district in which the property
is located. To take advantage of this provision,
rehabilitation expenditures must occur after
June 14,1976, and before June 15,1981.
The effect of this new section is that owners
will be encouraged to rehabilitate their historic
commercial properties because of the
availability of substantial tax savings in a short
period of time. Before the passage of the Tax
Reform Act, an owner was required to spread his
tax deductions over the life of the property; now
the deductions can be taken in five years.
b. Demolition, Section 2124(b) A new part,
Section 280B, "Demolition of Certain Historic
Structures," has been added to Part IX of
subchapter B of Chapter I of the tax code,
relating to items not deductible. It provides that
an owner or lessee of a certified historic
structure cannot deduct any amounts expended
for its demolition or for any loss sustained on
account of its demolition. Furthermore, the law
provides that any building or other structure
located in a Registered Historic District will be
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treated as a certified historic structure unless the
Secretary of the Interior has certified, prior to
the demolition of the structure, that it is not of
historic significance. This provision applies to
demolitions beginning after June 30, ] 976 and
before January 1, 1981.
For tax purposes, demolition costs or losses
sustained as a result of demolition must be added
to the capital account as part of the cost of the
land, rather than being deductible as part of the
cost of the replacement structure. The effect of
this provision is to discourage the demolition of
certified historic structures because taxpayers
will not be able to deduct these costs in later
years through depreciation.
c. Depreciation of Improvements, Section
2124(c) A new part has been added to Section
167 of the tax code, relating to depreciation.
This portion of the Tax Reform Act prohibits
the accelerated method of depreciation for any
property in whole or in part constructed,
reconstructed, erected, or used (after December
31, 1975 and before January 1, 1981) on a site
which was, on or after June 30, 1976, occupied
by a certified historic structure which is
demolished or substantially altered, other than
by a certified rehabilitation.
The effect of the provision is to discourage the
demolition of certified historic structures by lim-
iting taxpayers to the straight-line method of
depreciation, which provides less of a tax
deduction in the early years of a project than
does the accelerated method.
d. Substantially Rehabilitated Property, Section
2124(d) Another new subsection has been
added to Section 167 of the tax code, relating to
depreciation. Taxpayers will be allowed to
depreciate substantially rehabilitated historic
property as though they were the original users
of the property.
The law defines substantially rehabilitated
historic property as any certified historic
structure with respect to which capital
expenditures for any certified rehabilitation
during the 24-month period ending on the last
day of any taxable year, reduced by depreciation
or amortization deductions, exceed the greater
of the adjusted basis of the property or $5,000.
To take advantage of the provision,
rehabilitation expenditures must occur after
June 30,1976 and before July 1,1981.
The effect of this provision is to encourage
owners of certified historic structures to
substantially rehabilitate their properties
because they are allowed a more advantegeous
method of depreciation.
e. Transfers of Partial Interests in Property for
Conservation Purposes, Section 2124(e) Section
170(f) (3) of the tax code, relating to income tax
deductions for charitable contributions, was
amended by the Tax Reform Act. The act
provides that a deduction is allowed for the
contribution to a charitable organization or a
governmental entity exclusively for
conservation purposes of a lease on, option to
purchase, or easement with respect to real
property of not less than 30 years' duration or a
remainder interest in real property.
The law defines conservation purposes as the
preservation of land areas for outdoor public
recreation or education or scenic enjoyment, the
preservation of historically important land areas
or structures, or the protection of natural
environmental systems. Such contributions for
estate and gift tax purposes. To take advantage
of this provision, the charitable contributions
and/ or transfers must be made after June 13
1976 and before June 14 1977. This provision
has the effect of encouraging owners to grant
easements on their properties for conservation
purposes by allowing deductions in taxes.
C. Gettysburg National
Military Park
1. Critical Areas
In order to implement a new preservation
program at Gettysburg, the National Park
Service must have control over certain lands
now in non -Federal ownership. For purposes of
this report, these properties are termed "critical
areas."
The first preservation plan, known as the
Sickles' Plan, focused on the battleground south
of the borough and served as the basis for the
legislation creating Gettysburg National
Military Park in 1895. The Sickles' Map
recommended Federal ownership of 3,874 acres
for the purpose of preserving the most
significant lands associated with the Battle of
Gettysburg. This document has continued to
guide the Congress in its approach to land
acquisition at Gettysburg, although the enabling
act also states that the Federal Government
should also acquire "such other adjacent lands
as may be necessary to preserve the important
topographic features of the battlefield" (28 Stat.
651).
At present, the National Park Service needs
to acquire 374 acres to reach the 3,874-acre
limitation. Of these, 159 acres are now in the
process of being appraised for purchase. As
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Gettysburg National Military Park
Easl Cavalry Field
Gettysburg
Legend
| | Federal Land
^ Authorized Acquisition
| Critical Areas
-------
previously noted, general opposition to
acquisition has been related to the loss of tax
revenues, and the new Payment in Lieu of Taxes
Act should do much to change attitudes and
justify controls over critical parcels.
One problem with the land program is that the
National Park Service has been instructed by the
Senate and House Appropriations Committees
to acquire any "public" property by donation,
or, if not, through a mutually agreeable program
of all concerned. The most difficult acquisition
under these terms is the purchase of 55 acres of
public lands owned by Adams County, which are
extremely important in preserving the site of the
first day of battle. At this date, no satisfactory
agreement has been made to preserve and
interpret these vital historic lands.
In addition to the 374 acres identified by the
National Park Service, there are some other
historic lands over which control is advisable.
These include 139 acres on the first day
battlefield, 171.5 acres on the second day
battlefield, 103 acres (the Brown Farm) west of
the field of Pickett's Charge, 4 acres at the
bottom of Cemetery Hill, and 498 acres at East
Cavalry Battlefield. The map on page 5 shows
these areas as well as existing Federal holdings
and those presently authorized for acquisition,
Except for 10 acres, scenic easements or some
other partial interest in the land appears
sufficient to accomplish preservation goals. In
addition, the present authorization does not
provide for the acquisition of lands for a park
road corridor for access to the new visitor
contract-orientation center fromthe proposed
U.S. 30 Bypass. About 14 acres will be required
for this purpose.
2. Steimvehr Avenue
There are ways other than acquisition in fee or
through easements to mitigate intrusions near
the climactic scene. The sign ordinance of the
Borough of Gettysburg will do much to
eliminate large, vivid signs and billboards on
Steinwehr avenue when it becomes fully
operative on November 18,1978. Further
mitigation of the adverse effects of the
commercial strip on the battlefield and
cemetery are possible. The borough could enact
an ordinance to control paint colors and require
landscaping in order to reduce the brilliancy of
commercial structures and create a vegetative
cover between them and the prime historic
resources they abut. The Department of
Landscape Architecture of Pennsylvania State
University has indicated that it would prepare a
landscaping plan for a three-block area of
Steinwehr Avenue for $7,500. The purpose
would be to show owners what might be done to
beautify the avenue, and, at the same time,
protect the historic values of the battleground
and cemetery. It would appear to be in the best
interest of the National Park Service to finance
this project and sponsor other studies and efforts
aimed at upgrading the environment of the
Borough of Gettysburg. For example, the
National Park Service might fund the services of
a historical architect for Historic Gettysburg-
Adams County, Inc., to assist owners of historic
buildings in the Gettysburg Battlefield Historic
District in the preparation of restoration and
rehabilitation plans. The National Park Service
has been providing technical assistance to non-
Federal entities over many decades under a
variety of authorities, including the Historic
Sites Act of 1935, the Park Planning Act of June
23, 1936 (16 U.S.C. 17k), and the National
Historic Preservation Act of 1966.
In the case of Steinwehr Avenue, the ideal
would be to phase out strip development and
replace it with more compatible land uses. It has
been suggested that the National Park Service
provide space at the site of its proposed visitor
contact-orientation center for commercial
activity and grant the businesses located on
Steinwehr Avenue the right of first refusal on
development opportunities there. The
recommendation, however, did not take into
account legal problems involved in taking such
an action. The National Park Service has
authority for concessionaires in many parks, but
permits are usually granted to satisfy demands in
isolated areas. However, on October 19, 1976,
the President signed into law the Public
Buildings Cooperative Use Act (Public Law
94-955) which, among other things, "encourages
the location of commercial, cultural,
educational and recreational facilities and
activities within or near public buildings."
The new authority to encourage mixed uses at
Federal installations is further justification for
implementing the recommendation, which
indeed may be the best practical and equitable
means of restoring the historic character of the
battlefield and cemetery in that area.
3. Other Intrusions
Two other intrusions near the cemetery and
the climactic scene of the battle are the Electric
Map Building and the Cyclorama Center, both
owned by the National Park Service. Plans call
for the removal of the former with the
completion of the proposed visitor contact
orientation center. Long-range plans should
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t
also call for the relocation of the Cyclorama
Center. Presently, the National Park Service
could minimize the visual intrusion of that
facility by screening, and by painting of the
building a color more compatible with the
landscape and vegetation.
The most intrusive development near the
climatic scene is the National Gettysburg
Battlefield Tower. The Council reaffirms its
earlier position with regard to the tower and
urges the Secretary of the Interior to seek
appropriate legal action that will result in its
removal from the scene.
4. Helicopter Flights
Another problem is the regulation of
helicopter noise and related intrusive effects of
overflight in the area of the Gettysburg National
Military Park and adjoining historic sites. At
present the key to the control of the helicopters
and their operations around the military park is
local zoning. The existence of the present AG
Rotors heliport is important, inasmuch as any
zoning that might be adopted in the township or
county in the future would almost certainly have
to recognize the helicopter as a pre-existing
nonconforming use, or might ratify its presence
as a confirming use by establishing a separate
zone for it. While it is reasonably remote from
the sections of the battlefield that might be most
vulnerable to the generally higher noise levels
associated with take-offs and landings,
approaches and departures, it is in effect a
permitted use dually sanctioned by the local
jurisdiction. While this enterprise seems to enjoy
something of a monopoly at present, there is
nothing to discourage the establishment of
several other heliports or helipads for AG
Rotors or competing services. Looking ahead,
the absence of specific prescription for heliports
and helicopter operations, including prescribed
routes for sight-seeing flights and travel to
agriculture sites for crop spraying, to other
airports for passenger service, and to industrial
sites for parcel delivery, etc., indicates a
condition of potentially severe vulnerability to
aggravated environmental problems associated
with helicopter operations in the general area of
the battlefield and related historic sites. Some
degree of protection other than zoning may be
accomplished through the adoption by the
Federal Aviation Administration (FAA) or
regulations concerning helicopter noise. The
FAA is testing helicopter noise output at Dulles
Airport under a variety of conditions with the
objective of developing appropriate
environmental noise regulations sometime in
the future.
The National Park Service has had several
meetings with FAA concerning helicopter
flights over Grand Canyon National Park, and
further consultations may suggest ways to
control undesirable flights in nationally
significant areas. From our research, it would
appear that several parts of the basic Federal
Aviation Regulations (FARs) apply to
helicopter operations and offer some potential
for establishing an appropriate framework of
controls for helicopters as they might affect the
Gettysburg National Park.
a. Part 36 This is the basic element of the
FAR affecting aircraft noise in general, and it
does not apply to helicopters. This is an
unfortunate omission, but in view of the
magnitude of noise problems associated with all
other types of aircraft and the tortuous history of
the development of this regulation over a ten-
year period, the exclusion of helicopters is
understandable. It is reasonable to expect this
omission to be corrected after appropriate
studies by FAA.
b. FAR Part 91, Sec. 91,79.d This section
provides for a waiver of minimum altitude
requirements where sufficient justification can
be shown without compromising flight safety of
persons on the ground. Inasmuch as Part 91
applies generally to all aircraft, the language
that permits aircraft to be operated at less than
the minimum altitude specified for most aircraft
applies particularly to helicopters; thus, many
helicopter operations of the sort characteristic
of the Gettysburg battlefield area operate under
a waiver of this basic part of the FAR. The
conditions of the waiver should be examined to
verify whether any periodic renewal is required
in relation to experience gained after the
original granting of the waiver and whether any
additional conditions should be established.
c. FAR Part 91, Sec. 135.69 This section
governs the granting of certificates for
helicopter operations, and provides the basis for
area limitations and operations of helicopters.
New York Airways, a helicopter air taxi service
linking the major airports in the New York
region, operates under such a certificate. The
routes that New York Airways helicopters may
use to link their various destinations are
prescribed by the FAA Administrator. All pilots
are required to learn these routes in their regular
training programs. The routes are carefully
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mapped to follow waterways and nonresidential
areas wherever possible to minimize the
environmental noise problems that helicopters
often cause.
d. FAR Pari 91, Sec. 135.89 This regulation
governs emergency leading procedures, and
may also afford a basis for regulating helicopter
flights in the Gettysburg area. This section
prescribes minimum altitudes under a variety of
conditions to insure that helicopters have
sufficient altitude to permit safe landing under
autorotation or other emergency conditions.
The height at which helicopters are often seen
over the Gettysburg battlefield area is probably
not sufficient to comply with the requirements of
this section, but this would have to be checked.
c. FAR Part 91, Sec. 135.91 This section
prescribes additional minimum altitude
requirements over congested areas, and also
may afford some basis for dealing with the
problem of helicopters or Gettysburg. It is
doubtful, however, that much of the battlefield
would qualify as a congested area, even though
there are pockets of relative congestion,
particularly in the vicinity of the visitor center,
at many times of the year. It would probably be
necessary to broaden the typical definition of
"congested area" and explore with the FAA an
interpretation that might be applied to the
Gettysburg battlefield sites where people
assemble in substantial numbers.
5. Park Historic Resources
It should also be noted that the historic
resources under the protection of the National
Park Service at Gettysburg National Military
Park need immediate preservation treatment.
The park recently prepared a "List of Classified
Structures" that, for the first time, represents an
accurate inventory of this physical assets. The
study shows that 3.1 million dollars will be
required to bring these resources to an adequate
level of preservation. One-half million is
needed to repair monuments on the battlefield,
and 2.6 million dollars are required to restore
deteriorating historic structures. In view of the
importance of Gettysburg battlefield, the
National Park Service should give high priority
to this item in it budgeting and staffing process.
D. Eisenhower National Historic
Site
Presently, the 593 acres of the Eisenhower
National Historic Site are protected from
intrusions only on its east boundary, where the
farm joins Gettysburg National Military Park.
On the north and south there are open
farmlands, while to the west a number of new
residential units are beginning to disrupt the
historic setting.
In order to provide the Eisenhower farm with
adequate lands for development and protect it
from intrusions, it has been proposed that
certain lands on the south and west be acquired
whether in fee simple or by scenic easement.
The preferred method in most cases may be
scenic easement. Recommended as the south
boundary line is the 580-foot ridge, the site of
the South Cavalry Field engagement of the
Battle of Gettysburg. On the west, it is the
natural boundary formed by Marsh Creek and its
historic covered bridge. These lands consist of
the 195 acres held by the National Park
Foundation, 19 acres owned by the Gettysburg
Municipal Water Authority, and approximately
903 acres in private ownership. Of the latter,
544 acres are in three large farms. One large
156-acre tract initially offered to the Federal
government has been subdivided. Legislation
will be required to protect the 493 acres of the
present Eisenhower Farm by ensuring the
protection of the additional 1,117 acres.
E. Preservation of the Historical
Setting: Expanding the
Preservation Concept
A basic step in a new preservation plan for the
Gettysburg area is a broadening of the concept
of what needs to be preserved.
While narrow in scope, the Sickles' Plan was
sufficient for its day. In those times,
preservationists sought to protect significant
portions of the ground on which the most
dramatic events occurred. Those promoting
preservation gave little thought to the setting for
the battlefield; development did not threaten to
encircle the park: the pastoral scene was there
for all to see an enjoy. While Americans placed
great value on the property, the meaning of the
Battle of Gettysburg had not been fully assessed.
We know now that it was one of the most
significant events in American history, not only
because of its importance in determining the
outcome of the Civil War, but because of the
symbol it became.
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Eisenhower National Historic Site
Gettysburg National Military Park
Whealfield Road
West Confederate Avenue
\\ illmi^hln
Run
Kmniitsbur); Road
Black Horse
Tavern Road
Marsh Creek
Legend
^ Eisenhower Farm
Critical Area
i—i—i—i—i—i
o "Oj
% % %%%
Scale in Keel
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The major failing of the Sickles' Plan was that
it did not recognize the town as an integral part
of the battle. In the beginning, it was the town's
road system that drew Confederates to
Gettysburg. Both Union and Confederate troops
finally assembled at Gettysburg and not
elsewhere simply because it was central, and all
roads led to the town. Particularly on the first
day of battle, the town was the scene of heavy
fighting. The First and Eleventh Corps of the
Union Army, forced from their positions west
and north of town, retreated through
Gettysburg, where many were captured.
Throughout the battle, inhabitatnts secreted,
sheltered, and fed Union stragglers. There are
also many associations with Lincoln's visit to
Gettysburg at the time he gave his immortal
address.
Recognition of the importance of the town as
a historical resource has been quite recent,
beginning in 1972 with its designation as a
historic district under the laws of Pennsylvania.
However, designation pertained only to a 25-
block area, which does not include all Civil War
era structures, and the emphasis is placed on
preserving buildings that remain from the 19th
century. Federal recognition of the intimate
realtion of the town and battle did not come
until March 18, 1975, when the Gettysburg
Battlefield Historic District was listed in the
National Register of Historic Places.'* The
district includes the proposed 3,800 acres of
Gettysburg National Military Park, an estimated
1,200 acres of the Borough of Gettysburg, the
proposed 1,600 acres of the Eisenhower
National Historic Site, and an estimated 3,100
acres of Cumberland, Straban, and Mount Joy
Townships, other than the park and farm. As
estimated 9,600 acres comprise the primary
battle action, and in addition, there are 1,300
acres of East Cavalry Field in Mount Pleasant
and Straban Townships where the mounted
action of July 3, 1863, took place.
While a giant step forward, the Gettysburg
Battlefield Historic District does not contain all
of the lands that are an essential part of the
historic scene. The most fragile resource is the
scenic setting for the town, battlefield, and farm.
The Wallace/ McHarg study noted that the
natural beauty of the Gettysburg area is one of
its primary assets, and it remains generally the
same natural scene of historic times. This scene,
setting, vista, view, or whatever one wishes to
call it, gives the area a sense of place and
atmosphere that contributes greatly to the
ability of the visitor to understand and
appreciate the remains that are left and the
events which ocurred there. In ] 886, a local
history described one of the views as follows:
No natural panorama in the world surpasses
that which the spectator beholds when, standing
on the west of Cemetery Hill, he looks down
upon the broad expanse of field, meadow and
woodland, dotted with farm houses and barns,
the deep red of the newly-turned-up soil in
strong contrast with the verdure of growing
crops and magnificent groves, and the whole
landscape bounded by the outside mountain wall
as far as the eye can reach.
While there are some significant intrusions,
enough of what was present then is still there
today, and its preservation should be
encouraged. The map that follows on page 11
shows the area that makes up the historic setting.
In order to develop a comprehensive plan, these
views must be formally recognized either by
inclusion in the Gettysburg Battlefield Historic
District or by a revision of park boundaries by
the Congress. This area is also historic in its own
right, comprising the first land grant in the
region known as the Manor of Masque.
Designation in either case will make Federal
programs that provide technical and monetary
assistance for historic properties applicable in
this area, and make it possible for the
jurisdictions and individual property owners to
receive aid and encouragement in preserving the
scene. However, revision of park boundaries
would make it possible for the Federal
government to protect views through
cooperative agreements, scenic easements,
regulation and the like, and to combat major
proposed intrusions when necessary by the
exercise of the power of eminent domain.
The recognition by the Congress of the
historical value of large land areas without
specific reference to particular properties is not
uncommon. For example, the Congress in
considering the establishment of Nez Perce
National Historical Park recognized a 12,000
square mile area in Idaho as having importance
in American history, and in the Act of May 15,
1961 (79 Stat. 110) directed the Secretary of the
Interior to encourage preservation in this region
by a variety of means, including limited
acquisition when necessary.
While the map on page 13 generally shows the
area that comprises the setting, it should not be
construed to mean that all lands within it are
* See map showing the Gettysburg Battlefield
Historic District on page 11
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Boundaries of Historic Sites
Legend
Gettysburg National Historic I'ark
Gettysburg Battlefield Historic District
(State Nomination to National Register)
^ Eisenhower National Historic Site
Scale in Miles
E-17
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essential to preserving the view or that a single
land use must be perpetuated. For example,
substantial development could occur behind
ridges or at low elevation which could not be
seen from the battlefield or farm. Landscaping
could hide low-rise development at higher
elevations, and painting of modern structures
would be effective in reducing visual impact,
especially as the distance increases from
Federal properties. A study to define essential
areas within the zone will be necessary.
Furthermore, within this large area there are
locations undoubtedly more vulnerable to
development and at the same time especially
critical to the integrity of the historic views than
many other areas within the defined acreage of
visual sensitivity. These areas of high priority
can be identified by additional analysis of land
use patterns, by the inherent developability of
some of the land involved (much is extremely
rocky, steep, or poorly drained and therefore
not especially susceptible to immediate
exploitation), by patterns of ownership, and by
the level of access that such sites may have to
essential utilities, including roads, sewers, and
water systems. Thus, the protectors of the
historic and scenic interests of the battlefield
and its surroundings may come to a fairly sharp
focus on sites within the areas most in need of
early action to ensure the integrity of the pattern
of protection. Obviously, it is impractical to
impose equal levels of protection on all of the
scenic areas involved, but local interests as well
as the Federal interest can benefit by the
definition of the relatively limited acreage
actually vulnerable to development that should
be controlled on a high priority basis.
Local, State, and Federal governments could
investigate several measures, which separately
or in combination, could greatly help to
preserve the historic setting but do not require
outright fee purchase or easements. Some of
these methods might also be applied to protect
the critical areas previously defined for
Gettysburg National Military Park and the
Eisenhower National Historic Site. These
measures include:
1. Local Action
a. Cumberland Township: Planning and
Zoning Cumberland Township is presently
considering measures that would begin to
protect the area immediately around the
battlefield and farm. It has prepared a
"Comprehensive Land Use Plan" that attempts
to anticipate growth in a way that—although an
admitted compromise—takes into account the
E-18
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The Extent of Historic-Scenic Area
Legend
0 (>cttyshurj> National Military Park
and Eisenhower Farm
Ilisloric-Scenic Setting
Butler
E-19
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value of historic resources. (For a full discussion
of the plan and its probable effects see Part III of
the Appendix.) It is appropriate that the local
government is taking the initiative, and its effort
should be commended. Full encouragement
should be given to the township to adopt the
plan and implement zoning based on its goals.
Hopefully other townships within the historic
zone will do the same, although action in the
forseeable future is doubtful.
b. Scenic Overlay Zoning One technique used
by localities to preserve the natural scene is
called overlay zoning. Preferably with
incentives and encouragment by the county
government, Cumberland and other townships
within the area of visual impact could develop
open space plans to be overlaid or superimposed
on traditional planning zones. The method
utilized in other localities has been to give
preference in the overlaid zone to preservation
of the scene by modifying the particular land use
already sanctioned. This is accomplished
through the development of standards that
prescribe such things as the type of construction
or the vegetative treatment needed to eliminate
or minimize visual impact. An example would
be that construction in an area already zoned
residential might be permitted, but at a lower
elevation or at a decreased height.
c. Local-Federal Cooperation to Preserve a
Scenic District One method of preserving a
scenic district aroung a national park involves a
good deal of local and Federal cooperation and
is a possibility in Pennsylvania. Presently under
consideration in Tredyffrin Township is a
zoning ordinance to establisha scenic historic
district near Valley Forge National Historical
Park. While this ordinance might have indirect
Federal participation, it does not call for State
legislative action.
Included in the proposed ordinance is the
proposed designation of a "scenic district"
within 3,600 feet of the perimeter of Valley
Forge.
No new construction or development can
occur in the district if it will detract from or
conflict with historic values. Construction is
allowed if it is naturally shielded from direct
observation from within the park. A further
"Scenic Peripheral District" is being proposed
in a radius of 3,600 to 7,200 feet from park
boundaries, While less rigid construction
guidelines are proposed in the peripheral zone,
construction will not be allowed to detract from
the scenic view. Also under consideration by the
local government is another proposal that would
allow the scenic district to be expanded from
time to time to include any area certified by a
designated official of the National Park Service
as being within the line of sight.
d. Placement of Public Utilities Public utilitiy
commissiones could prevent extensions of mains
into the historic zone when they would
encourage development that conflicts with the
goals of preservation. Action by these
commissions is essential in order for the new
program to succeed.
2. State Action
a. State land Use Management More and more,
State government see themselves as strategically
situated to plan and manage the environment,
particularly in matters of land use management.
Some States are coming to the conclusion that
local governments are too close to economic
and political pressures which help create
environmental problems to be sufficiently
detached. Furthermore, perspective is limited to
their jurisdictions, although environmental and
scenic protection problems often go beyond
political subdivisions. In many cases, States
have decided local governments lack the
financial tools and professional capabilities to
do a proper job of environmental management.
There is a definitive trend in State government
to reclaim the traditionally delegated power to
control land use. For example, the State of
Florida under its policy for "Areas of Critical
Environmental Concern" includes improper
management of historical resources as one of the
reasons for abrogating control by local
governments.
In May of 1971, the voters of Pennsylvania
approved an amendment to the Pennsylvania
Constitution which reads:
The people have the right to clean air, pure
water, and to the preservation of the natural
scenic, historic and aesthetic values of the
environment. Pennsylvania's public natural
resources are the common property of all the
people, including generations yet to come. As
trustee of these resources, the Commonwealth
shall conserve and maintain them for the benefit
of all people.
The State has not yet enacted legislation that
would interpret the amendment so that it can be
clearly enforced. It is hoped that the
Commonwealth of Pennsylvania will consider
these most important historic resources as
worthy of a plan for environmental protection
either in the absence of local control or in
concert with local protection.
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A recent example of State action is Vermont's
Land Use and Development Act, which has
environmental protection as its major goal. One
of the objectives is to regulate large-scale,
physical growth within the State in order to
promote polution control, esthetic values, and
protection of open space. Very little local
zoning existed in Vermont at the time of the
passage of the act, and vacation home
development and related construction
threatened impairment of the State's unique
scenic beauty and natural resources. The law
created a partnership in which the State
oversees areas outside local government
jurisdiction or unzoned areas, as well as large-
scale developments that may be too politically
difficult for a small town to control.
b. Federal Participation in Local Zoning One
of the major recommendations of the
Wallace/ McHarg study was the creation of a
joint planning body consisting of Cumberland
Township, the Borough of Gettysburg, and the
National Park Service. Partly because of a lack
of planning history in the area and because of
the necessity for new authority, a joint planning
body, which would have been an innovative
step, was never formed.
The participation of the Federal Government
in the administration of local zoning implies the
partial surrender of the duties and authorities of
the municipalities. To achieve this end, action
by the State legislature would be needed.
Another possibility would be the creation by the
State legislature of a zoning district comprised
of private lands within the boundaries of the
authorized Federal area that would not be taken
by eminent domain if developed within the
framework of park objectives. Such an act could
set limitations on uses and provide for the
establishment of a joint planning commission.
Specific methods of joint local-Federal zoning
would have to be tailored to the requirements of
the Constitution of the Commonwealth of
Pennsylvania.
c. State Tax Incentive for Preservation of
Agricultural Land Much of the land found
within the area of visual impact is in agricultural
use, just as it was at the time of the battle in
1863. This land use should be encouraged.
Under Pennsylvania statute, a county or other
municipality is authorized to designate
agricultural "preserves." The law makes it
possible for landowners within the preserves to
sign an agreement with the municipality
accepting agricultural restrictions on the land in
return for a reduction in assessed valuation.
Under this arrangement the land can be assessed
on the basis of its agricultural productivity
rather than, for example, on its potential value
as a development site. The impetus of the
legislation is the preservation of prime
agricultural land. However, amendment of
similar legislation in other States has permitted
inclusion of other open space lands for
conservation purposes.
This kind of legislation for the preservation of
agricultural land has been criticized in concept
because it does not provide for permanent
protection of open space and can be used to
lower holding costs for long-term speculators.
The voluntary nature of such acts and their
dependence upon initiative by local government
in establishing preserves have further limited
the fulfillment of State objectives.
In Adams County, little incentive exists for
farmers to enter into preserve agreements
because tax assessment of agricultural land is so
low. This is a situation subject to change as
pressure for development occurs on land close
to Gettysburg. The act can be effective as a
short-term measure, and its use should be
encouraged. An amendment that would allow
State payments to municipalities to recoup some
of the foregone property taxes would make its
use more attractive to local governments.
3. Easements and Federal Lease-Back and
Sell-Back
There are two other methods that could be
applied in the area comprising the historic and
natural scene which do involve large public
expenditures. These techniques might be used to
control small parcels that turn out to be prime
sites for intrusive development. An in-depth
study of the area, as previously recommended,
will define these parcels. It should also be
remembered that Federal easements and lease-
back and sell-back arrangements are possible
only within or near the authorized boundaries of
a national park area.
a. Easements Scenic easements are a practical
means of control in certain circumstances.
Where the land is not yet under heavy
development pressure, such as is the case in
most of the areas of concern near the Gettysburg
National Military Park and Eisenhower farm,
the initial costs for scenic easements are often
substantially less than for outright fee
acquisition. The property remains in private
ownership so owners are not displeased and the
government does not have to assume the
administrative expenses of a large-scale land
holding operation. The property also remains on
the tax rolls, although the assessed values
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1-21
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should certainly be lowered.
A scenic easement would not interfere with
the possession or basic title of the owner, who
continues to have all the rights and benefits of
ownership, except those specifically restricted
by the terms of the scenic easement document.
A scenic easement is concerned primarily with
controlling future uses of the land.
b. Federal Lease-Back and Sell-Back Another
method of direct Federal action to protect land
adjacent to national parks that has been applied
in the past is "lease-back and sell-back." This
method has been Congressionally authorized in
at least two instances: at Antietam National
Battlefield and at Piscataway Park. In the
Antietam case, in 1960, Congress authorized the
acquisition of the outright fee and immediate
reconveyance to the former owner, subject to a
new deed covenant or a scenic easement
retained by the Federal Government.
In 1966, Congress authorized acquisition of
the fee in a described area adjacent to
Piscataway Park. The legislation authorized the
Secretary of the Interior to convey a freehold or
leasehold interest in property acquired, subject
to conditions that assure him control over the
property and its use in accordance with the
purposes of the park. Sales or leases were to be
made to the highest bidder with receipts going
into the Land and Water Conservation Fund.
The Piscataway method of control does not
depend upon either local zoning, the willingness
or ability of the landowner to withstand
economic pressure, or upon suspension of
Federal condemnation. It relies on traditional
methods of covenant enforcement. The major
disadvantage of this method is that it may
require the appropriation of funds sufficient to
acquire the fee in all the property within a
designated area. This would be partially offset,
however, through the subsequent sale or lease of
such lands.
The lease-back and sell-back of development
rights of lands owned in fee often involves the
public policy issue of the taking of one person's
property and the selling or leasing of it to
another. This is not a new method in Federal
programs, and is essentially the tool to
implement the Federally-funded urban renewal
programs of the past 25 years.
4. A Final Alternative
Each of the proceeding alternatives
concerning what can be done to protect the
important and nationally significant cultural
values inherent in the Gettysburg area—
acquisition, land use controls, Federal purchase
of development rights, Federal lease or sell
back, Federal participation in local zoning or
Federal-local cooperation—rests on a premise
that the Federal government must either
purchase protection or cajole the State and I or
local governments to act to protect such
nationally significant values. However, there is
another non-monetary solution—authorization
for the National Park Service to regulate and
control detrimental land use activities. Legal
research concerning other areas of the National
Park System has concluded that there is
Constitutional authority to regulate private
lands to protect national holdings and that the
Constitution also appears to authorize the
regulation and protection of nationally
significant resources regardless of ownership.
Accordingly, a final alternative is to seek
Congressional approval to establish a federal
regulatory framework within which at least the
most critical national interests could be
protected—without acquisition—should the
State and/ or local governments fail to act in a
responsive fashion.
Such an approach would require the shaping
of new legal tools; could stress the traditional
governmental authorities in the Gettysburg area;
and it could also, perhaps inevitably, lead to
another landmark case concerning the balance
between preservation of deeply significant
national values and State, local, and private
prerogatives. Nevertheless, the protection of the
Gettysburg environment is, in a real sense, a
responsibility of trust to all citizens of this
country. Such a responsibility cannot be
ignored.
These, then, are some of the things that can be
done to institute a new era of preservation.
Many of the problems that beset Gettysburg are
common to other national park areas, and some
of the solutions suggested in this report might be
applied elsewhere. If there is one truth to be
learned from the Gettysburg experience, it is
that one jurisdiction or one agency of the
government cannot be expected to deal
successfully with all the problems that demand
treatment. A consortium approach to Federal
planning appears to be the only means of
accomplishing the objectives of preserving the
best of our historic properties.
E-22
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Appendix Parti
The Federal Properties
A. Gettysburg National Military
Park
The Battle of Gettysburg was the climactic
engagement of the Civil War. General Robert E.
Lee's Confederate Army of Northern Virginia
had invaded Pennsylvania in 1863 to move the
arena of war and devastation from Virginia to
the rich North, hoping to give the Old Dominion
a chance to recuperate, to disrupt Federal
military operations in the East, and to win a
victory that might be decisive. The
Confederates encountered George G. Meade's
Army of the Potomac west of Gettysburg, and
nearby forces gathered rapidly. On July 1,
portions of the two armies met west and north of
the town in a bloody battle classic in its
illustration of the tactics of that time. Having
superior numbers, the Confederates prevailed
and drove the remnants of decimated Union
regiments through the town south to Cemetery
Hill, where they rallied and prepared to fight
again.
The armies concentrated rapidly that night,
and on the following day 170,000 men with
horses and equipment gathered in and about the
rural community. The Union Army occupied a
hook-shaped position on Cemetery Hill,
Cemetery Ridge, Culp's Hill, and the Round
Tops; the Confederates formed in a concentric
line on Seminary Ridge, in the town, and
northeast of Culp's Hill. July 2 was a day of
great confusion and little coordination, savage
fighting, and Federal improvisation. The left of
the Union force advanced from its line on
Cemetery Ridge to tempting ground along the
Emmitsburg Road in a movement that
occasioned one of the lasting controversies of
the war. The Confederates assaulted this new
attenuated line in heavy but uncoordinated
attacks and destroyed it, making the place
names of that action—Little Round Top, Devil's
Den, The Wheatfield, and The Peach Orchard—
household words. But their success was partial
and Pyrrhic. The Confederates also gained some
success that night in an attack on Culp's Hill
but, after prolonged fighting on the following
morning, the Federal army eliminated these
gains.
There were two dramas on the afternoon of
July 3. One of the greatest cavalry battles of the
war, a drawn fight, took place in the fields three
miles east of Gettysburg (the area remains
essentially pristine, but little of it is in public
ownership). At the same time, a mighty artillery
duel was taking place on the main field as Lee
prepared to attack the Union center. This thrust,
"Pickett's Charge," was one of the grand
spectacles of American history. After two hours
of incessant cannon fire, 12,000 Confederate
infantry in well ordered lines carried their
colors toward Meade's center on Cemetery
Ridge but failed to break the Union line. The
Army of the Potomac had prevailed, and Lee
ordered his crippled army back to Virginia.
Never again in the two years of war that
followed would he be able to launch a major
offensive
Nearly 10,000 men were killed or mortally
wounded and buried in shallow graves on the
field. In order to provide decent burial for the
Federal dead (the Confederates were removed
to the South after the war), Governor Curtin of
Pennsylvania and his agent David Wills
purchased 17 acres on Cemetery Hill for what
became the Soldiers' National Cemetery. It was
at the dedication of this cemetery on November
19, 1863, that President Lincoln gave his
Gettysburg Address.
Soon after the battle and the establishment of
the cemetery, some Gettysburg citizens began
one of the nation's major pioneer preservation
movements with the goal of preserving the
battlefield as a national shrine. The vehicle for
this movement was the Gettysburg Battlefield
Memorial Association. Fueled by donations
from the northern states, particular those having
troops in the battle, the Association's aim was to
acquire land occupied by the Federal forces,
place monuments upon it in the positions
occupied by the regiments that had defended it,
and develop avenues by these memorials to
make them readily accessible to visitors.
The Association drafted simple but effective
rules governing the materials used for memorials
and their inscriptions and location, and,
appealing to State pride, succeeded in obtaining
state cooperation. The Association's board was
essentially local until the 1880's, when it was
taken over by the Grand Army of the Republic.
The Association existed until 1895, when its
debts and assets, including 500 acres of land and
300 monuments, were transferred to the War
Department and the new national park.
A park commission of three men had been
formed in 1893 to mark positions of both armies
on the field, open avenues, purchase or
condemn needed land, accept the donation of
land from the Association, and to do historial
research needed to accomplish their task. It was
this commission that was on hand at the creation
of "Gettysburg National Park" two years later to
take control both of the Federal land therein
apart from the cemetery, and the land of the
Association.
E-23
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Battle of Gettysburg
Legend
I} Confederate
O Union
To Carlisle
To Harrisburg
To Qiambenburg
To Hagerstowj)
Oak Ridge
Oak Hill
V (o
MfPhcwj
Rittmc Qf College
lo Philadelphia
Herr Ridge
?e s Headquarter
Benner >
Hill
Getmtu
To Hanover
emctary Hill
July 3 ^1^
O/ 11/ «^»P
eade's\SPan«!>^
/Pirbniiv rV ( nl
Seminary
Pickett's C Y f uAadquartiA P'r'K
Hieh Water Mark
olf Hill
Cemetdty I Power's Hill
Ridge
Orcha
Rock Creek
fo Baltimore
at field
iPs De
Roynd Tof
¦y Big Roymrr^p
Cavalry
Battlefield
To Washington
To Taneytown
Hanover Road
Witloughby4fcun
Scale in Miles
E-24
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In the 1890's the battlefield was the subject of
a key Supreme Court decision in the historic
preservation movement. It had been bisected by
•a railroad spur that ran south from the town
across the field of "Pickett's Charge" to the rear
of Little Round Top. Then, in 1893, the spur
was incorporated into a trolley line designed to
carry visitors on a loop over much of the field,
dropping them at designated stations at key
points along the way. Although broad avenues
for horse drawn vehicles had been located
throughout the park, the work of the "trolley
vandals" was not to be tolerated. Congress
agreed and passed a resolution urging that the
trolley holdings be condemned. This was done,
but the trolley company, the Gettysburg Electric
Railway Company, appealed on the grounds that
preserving and marking lines of battle were not
public uses permitting condemnation.
The appeal went to the Supreme Court, which
on January 27,1896, rendered the decision that
the condemnation had indeed been
constitutional and that the preservation and
marking of battlefields was a public use "so
closely connected with the welfare of the
republic itself as to be within the powers granted
Congress by the Constitution for the purpose of
protecting and preserving the whole country."
The War Department held custody of the
battlefield until 1933. During its management of
nearly forty years, it constructed approximately
30 miles of excellent avenues, acquired 2,116
acres of land, and managed the park as a great
memorial. In this period, in keeping with the
War Department's concept that battlefield parks
could be used for military training, the field of
"Pickett's Charge" became the site of Camp
Colt during World War I, and the Army utilized
the park for military training at other times. It
was during this period also, in 1915, that the
War Department took measures to control the
numerous persons who offered their services as
guides to tourists who visited the park. Only
such guides as were deemed capable were
licensed and authorized to charge prescribed
fees for their services within the park. This
special service has continued throughout the
years and must loom large in the early history of
park interpretation.
Although the Government added tracts of
land here and there, Gettysburg underwent few
changes prior to the mid 1950's. Park
headquarters was located in the second floor of
the post office in downtown Gettysburg, where
there was a large exhibit room decorated with
photographs of the park and the excellent relief
map of the battlefield area. Visitors to the park
used commercial guidebooks exclusively until
the 1930's, when the Service made its own
literature available to them. Field exhibits apart
from tablets and markers came into use during
the World War II period.
The end or World War II marked the
beginning of major changes at Gettysburg.
Travel increased and with it commercial
development. Vast improvements in highway
systems in the 1950's simplified travel to
Gettysburg, and park improvement, under the
Service's Mission 66 program, made the
battlefield more attractive.
This ten-year program was instituted
throughout the National Park System an effort
to repair and improve facilities that had suffered
from neglect during the war and that would be
needed to help the parks meet expected heavy
visitation. Mission 66 at Gettysburg meant a
number of things: the resurfacing of park
avenues, the construction of a new visitor center
and offices, the repair of the Gettysburg
Cyclorama and its installation in the visitor
center, new field exhibits and pullouts on the
park's auto tour route, a new High Water Mark
Walking Tour, and a new vehicle bridge over
the Railroad Cut. Coupled with Mission 66 in
this and other Civil War areas was a desire to
have facilities as complete as possible during the
Civil War Centennial.
Gettysburg had experienced a building boom
after World War II as had other communities,
but the Gettysburg boom threatened the
battlefield itself. The Colt Park addition
crowded the field of "Pickett's Charge," houses
went up on Oak Ridge and along the
Emmitsburg Road, and a subdivision threatened
the McMillan farm. During the late 50's and
60's commercial development, particularly
motels, sprung up along Steinwehr Avenue
followed during the centennial by numerous and
varied eating places and museums.
In this period, the park administration
countered pressures with limited success by
attempts to purchase threatened tracts of land.
Funds were scarce, and in the 60's their
expenditure was limited because of a restriction
imposed by Congress requiring local effective
zoning. Another factor inhibiting land
acquisition was the Federal Government's
reluctance to acquire real estate and remove
property from tax rolls. Too, land restrictions
existed in the form of a 3,874-acre ceiling
imposed through the Sickles' Map by the act
establishing the park. Numerous tracts of land
including those along the Baltimore Pike and at
the site of the great cavalry battle remain
E-25
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outside proposed boundaries, because they are
beyond the ceiling limit.
The park has been concerned for years over
the tracts owned by the Adams County Poor
Farm. These tracts, which are highly significant
in the first day's battle, cannot be donated under
State law, and by Congressional committee
decision they cannot be acquired by the park
except through donation. As a result, the county
sold some country land on the Carlisle Road
north of Howard Avenue, which has been
developed for commercial purposes. A few
years ago, a tract south of Barlow's Knoll, site of
the historic farm buildings, was slated for use by
the county's Vo-Tech School, a thoroughly
unacceptable intrusion. Because the proposal
included Federal funding from the Department
of Health, Education, and Welfare and because
the construction of the school at that location
constituted an adverse visual affect on the park
as a National Register property, the Advisory
Council on Historic Preservation reviewed the
action. In the course of review and the
discussion of efforts to mitigate the intrusion,
local parties found a suitable site off the
battlefield, and this threat dissipated. However,
permanent preservation of this tract has yet to
be accomplished.
No preservation problem at Gettysburg
engendered more heated reaction and debate
that that of Thomas Qttenstein's "National
Tower," described in the introduction of this
report. Another intrusion dealt with in recent
years is the Gettysburg National Museum of
"Electric Map," one of the oldest, if not the
oldest, private museums at Gettysburg. This
museum, located opposite the Taneytown Road
entrance of the National Cemetery, had a
visitation comparable to if not exceeding that of
the park's visitor center. The museum features a
large and fine collection of Civil War artifacts
and a popular program, but was objectionable as
a commercial venture opposite the National
Cemetery entrance. It was also an intrusion on
the historic scene and the word "National" in its
name proved misleading to many visitors, who
assumed it to be a park installation.
The park acquired the museum in 1972 and
now operates it through the Eastern National
Park and Monument Association. Although it
pleases visitors, many of the objections to it that
were leveled when it was a private enterprise
still remain and are strong arguments for its
removal. Plans call for its eventual demolition
and removal of its contents to a building at
another location. The disposition of the
"Electric Map" will be complicated, because
the township amusement tax collected as a part
of its admission fee provides a significant
portion of the township revenue. Thus,
interference with this tax could cause
repercussions and would no doubt be locally
unpopular.
Helicopters have also provided problems for
the park. During the centennial period a
heliport opened along the Emmitsburg Road a
short distance from the battlefield. The
proprietors offer rides over the park for a fee. At
times of heavy visitation, there has been
constant helicopter travel over the park creating
both a visual and audible intrusion. Although
the proprietors of this attraction have
cooperated by not routing flights near the
Cyclorama Center and National Cemetery, the
intrusion elsewhere remains.
The Service is preparing a new master plan for
the park that will replace that approved in 1966
and deal with problems and opportunities which
have become apparent since that time. This plan
will include the military park and national
cemetery but not the Eisenhower National
Historic Site.
The plan will, of course, address a variety of
park needs and facets of park management. It
will deal particularly with the problem of
visitors to the Gettysburg community as well as
the park and propose the location of a new
visitor center north of Gettysburg that will
accommodate travelers approaching the park
over a proposed Route 30 bypass. The target
date for the completion of this plan is May,
1977.
B. Eisenhower National Historic
Site
Eisenhower National Historic Site was the
last home of President and Mrs. Eisenhower,
and it was said to have been the only residence
they ever owned. Eisenhower had commanded
Camp Colt on the field of "Pickett's Charge'
during World War I and was attracted to the
Gettysburg area as a residence after retirement
from active military service. Thus it was in 1950
that he purchased a 230-acre farm adjoining the
park.
The Eisenhowers enlarged and modernized
the ante-bellum farmhouse and other buildings
and began raising cattle. During his presidency,
they used the farm as a retreat from the White
House, and in 1961 it became a full time
residence and remained Eisenhower's home
until his death in 1969. The same year the
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Eisenhowers donated the farm and house to the
Federal Government, and on November 27, it
was declared a national historic site. The
President retained a life estate in the farm, and
Mrs. Eisenhower occupies the house and 14
acres surrounding it under a special use permit
from the National Park Service.
The historic site contains 493 acres, the
Eisenhower farm, plus the Alton Jones property
that was managed as part of the Eisenhower
farm. The National Park Service proposes to
add other acreage to the west and south.
Additional land will include tracts that slope
from the farm to high ground along the
Emmitsburg Road and those encompassing the
Marsh Creek Valley immediately to the west.
The Eisenhower National Historic Site shares
most of the environmental problems of the
adjacent battlefield. Like that field, it is
threatened by numerous changes associated with
the increasing urbanization and development of
the area.
The problem with Gettysburg National
Military Park, Gettysburg National Cemetery,
and Eisenhower National Historic Site is that
while, with certain exceptions, much of the land
that is historic—the land where Eisenhower
walked, Lincoln talked, and soldiers fought—is
contained within park boundaries, most of the
setting for this land is not, and to maintain the
integrity of the former, it is necessary to
maintain the integrity of the latter. The purpose
of these parks is to preserve the appearance and
atmosphere at the time the events occured so
that others might experience them vicariously.
The ability, then, to preserve the essential
nature of the three Federal properties in the
Gettysburg area, as they are presently
constituted, lies with the jurisdictions that
surround them. It should be remembered, and
indeed, emphasized, that these non-Federal
jurisdictions contain significant sections of the
battlefield, and other historic resources worthy
of preservation, as well as encompassing much
of the historic setting for these areas. Just as
there are factors operating with the jurisdictions
to protect these resources, there are others that
work against preservation. In order to
understand the situation, we must take a close
look at the history, authorities and the political,
social, and economic motivators that
influence decision-making in the Borough of
Gettysburg, Cumberland Township, and Adams
County.
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Part 2
A. Settlement
King Charles II of England included the 526-
square mile area of South Central Pennsylvania
that today is known as Adams County in a grant
to William Penn in 1681. There is little
evidence of earlier Indian settlement. While
vanguards began to arrive in the area during the
early century. First to settle in what is now
Adams County were English Catholics, who
moved up from eastern Maryland in 1727.
Germans under Penn's authority arrived in
1734, and the Scotch-Irish settled in the western
area of the county in the second half of the 18th
century, becoming the most numerous and
influential group. Penn's claims conflicted with
those of the Calverts in Maryland, and
disagreement lasted until completion of the
Mason-Dixon survey in 1767. The Mason-
Dixon Line forms the southern boundary of
Adams County where it borders Maryland.
The three jurisdictions originally established
in Pennsylvania were Philadelphia, Bucks, and
Chester Counties. As areas to the west became
settled, others were formed for legal and
communication purposes, Lancaster being the
fourth, followed by York organized in 1749.
The first Pennsylvania county west of the
Susquehanna River, York originally contained
the area now in Adams County. The next step
was the creation of townships to serve as the
basic level of local government. In the mid-18th
century, Cumberland Township, now containing
the Gettsburg National Military Park, became
one of the twelve jurisdictions subdividing York
County. In the following decades, the area that
later came to be known as Gettystown grew as a
market center within the township.
By the turn of the century, population in the
western half of York County had grown
appreciably. Settlers had to travel over 40 miles
to the county seat in order to attend court, pick
up mail, and conduct public business. Because
of the distance, citizens petitioned the new State
government for a division, which resulted in the
creation of Adams County on January 22, 1800.
Named for the President at the time, John
Adams, the new county had a population of
13,172.
The settlement of Gettystown, soon to be
called Gettysburg, became the judicial center of
Adams County, the choice being partly made
because of an offer by the founder of the
settlement. James Gettys, and other citizens to
provide land and finance the construction of
public buildings. In 1800, Cumberland
History and Development
of Adams County
the Borough of Gettysburg
and Cumberland Township
Township had a population of 1,263, with
approximately 500 of those residing in
Gettystown.
In 1806, the State legislature passed an act
incorporating Gettysburg as a borough, allowing
the establishment of a form of government
distinct and separate from the township.
B. Adams County
The population of Adams County has grown
slowly, but steadily, since its creation. The slow
growth reflects the economy, which has always
been rooted in agriculture.
Lack of major growth also reflects the
bypassing of Adams County by any principal
transportation thoroughfares in the 19th and
20th centuries. Adams County had no part in the
canal period of transportation important in the
development of Pennsylvania and New York.
The railroad came late to Adams County, and
when it did, in 1858, it was a feeder line
between Hanover and Gettysburg. No interstate
highway routes cross Adams County, and none
are planned. Similarly, the area is not served by
an interstate airport.
The growth that has been conducive to a rural
lifestyle in the county is beginning to conflict
with the pattern of concentrated growth in
Gettysburg and Cumberland Township which
began after World War II. The conflict is and
will be evident when proposals for planning and
land use controls are discussed. The following
statistical chart shows population increases
from historic times to the present.
The 1970 population figure of 56,937, spread
over 526 square miles, still indicates a rural
area. Gettysburg and Cumberland Township are
the population core, accounting for about one-
fifth of the county's population. In all, the
county contains 33 municipalities: 21 townships
and 12 boroughs. T wenty-six percent of the
population is classified as urban, while the
remaining 74 percent is considered rural.
However, the latter categorization does not
necessarily mean a farming population. The
number of those involved in farming has, in fact,
been declining since World War II. Studies show
that approximately 85 percent of Adams County
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Jurisdiction
1800
1810
1860
1900
1940
1960
1970
Adams County
13,172
14,500*
28,006
34,496
39,435
51,906
56,937
Cumberland
Township
1,263
863* *
1,600
1,787
2,925
3,497
Borough of
(Jt'ltysburg
Not In
corpor
ated
725
5,916
7,960
7,275
* Approximate
* * Reflects Creation of Borough in 1806
residents classified as rural are non-farmers.
The development of Adams County has been
strongly influenced by its physiography.
Located on the eastern side of the Appalachian
Mountains, Adams County is in the southern
section of the so-called Great Valley, including
Cumberland, Lehigh, and Lebanon valleys, all
of which have rich, productive farms and
numerous small towns. The South Mountains of
the Appalachian Range, having many high
ridges, form the western boundary of the county.
Numerous orchards cover the foothills of the
South Mountains, helping to make Adams
County the largest apple processing center in
the world. Dairy and livestock farming are
found in the Gattysburg Plain and intermountain
valleys throughout central and southeastern
Adams County. Major portions of the South
Mountains in the western part of the county and
the Pidgeon Hills, near the eastern edge, are
covered with forests. The Commonwealth of
Pennsylvania owns large areas of these forest
lands as a conservation measure.
Two major watersheds almost equally divide
the county. About half of the area is drained
northward into the Susquehanna River by the
Conowago River and its tributaries, while the
other half of the county is drained south and
west into the Potomac River by the tributaries of
the Monocacy.
C. Adams County Government
and Planning
The State Constitution authorizes a county
governing body, consisting of a popularly
elected three-menber Board of Commissioners.
The commissioners' responsibilities include the
following:
C I) the preparation of county budgets and the
levying and collection of county taxes:
( 2) service as the Board of Elect ions
responsible for voter registration, preparation of
ballots, andofflcial ballot tabulation;
(3) responsibility for the building and
maintenance of county buildings and bridges. In
this respect, the commissioners handle the
disbursement of a "liquid fuels tax fund," which
is returned to the county by the Commonwealth.
Approximately 50 percent of this fund is used for
building and maintaining over 40 county
bridges, and the balance is handed over to
townships and -boroughs on a per capita and
mileage basis for the improvement of township
and borough roads. (The county itself does not
maintain roads.) All road improvements must be
approved by the Pennsylvania Department of
Transportation;
(4) responsibility for the county prison, and
for providing services and facilities to the county
courts and to court-related activities;
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(5) the power to make appropriations and to
authorize bonds with the approval of the courts;
and
(6) the authority to appoint all county
employees, except for those who serve other
elected officials.
The Board of Commissioners also appoints
the members of the Adams County Planning
Commission, who in 1965, were given the
responsibility of preparing a plan to guide
orderly development. The consulting firm of
Clifton E. Rogers and Associates produced the
Comprehensive Plan; Adams County in 1971.
The planning commission and the
comprehensive plan serve the county in an
advisory capacity. While the county may zone, it
has not yet done so, nor does it appear likely to
do so in the future. One of the reasons, which
will be explained in detail later, is that under
State law the zoning authority of the borough
and township is preemptive.
Planning activity has increased since 1972,
not only in Cumberland Township and the
Borough of Gettysburg, but in many of the 33
jurisdictions in Adams County. As of 1974, nine
municipalities had adopted comprehensive
plans; four others, not including Cumberland
Township, had plans pending adoption; 10
communities, primarily in northeastern Adams
County, had drafted zoning ordinances;and 24
municipalities had subdivision regulations.
The county's land use plan does not greatly
detail recommended land uses in the county. It
recommends reinforcement of the existing land
use patterns and does not conflict with the plans
and zoning ordinances of the varied townships
and boroughs. The fundamental
recommendation of the county planning
program regarding urban and urbanizing areas of
the county is, in fact, to encourage intensive
borough and township activity in planning and
land use control.
D. County Revenues and Economy
The total revenues for all of the general
operating funds of Adams County have
increased substantially in recent years. Between
1964 and 1972, county revenue rose from
$808,655 to $2,637,587. The principal source
of income is derived from the real estate tax,
which now accounts for about 40 percent of the
total revenue and over 50 percent of county
taxes. The county made Us last real estate re-
assessment in 1976, At that time properties were
assessed at 40 percent of market value, a figure
realistically below 30 percent of market value in
1976 dollars. There are no State or county
regulations determining the frequency of
assessments.
Other major county revenue sources include a
per capita tax of about six percent of total
revenue, and a personal property tax of four
percent. State grants provide about 12 percent
of the total revenue, and Federal revenue
sharing another six percent. The primary
expenditures of the county are for operation of a
county home and county jail, other correction
expenses, child welfare, and general
government, including the operation of county
courts.
Despite large amounts of land devoted to
agriculture in Adams County and attention
given to farm production, the major economic
activity is manufacturing, and trends in the
economy are dependent on the potential for its
growth. The value of farm production in the
county is estimated to be less than 25 percent of
the value of production in manufacturing. The
manufacturing activity of Adams County is
diversified, with a high proportion of effort
related to the furnishing of food and clothing.
The farm product of greatest value is fruit,
considerably above the next most important,
livestock.
E. The Borough of Gettysburg
The Borough of Gettysburg has continued its
traditional functions as a market and
governmental center. From the late 1940's and
into the 1960's, as population figures attest, the
Borough of Gettysburg filled in and residential
suburbs began to grow in Cumberland
Township, principally to the southwest and
northwest. At present no more substantial,
undeveloped parcels remain within the borough
limits, and a borough zoning height limitation
will probably ensure a continued spreading-out
growth pattern. Annexation of Cumberland
Township areas by the borough is not seen likely
in the foreseeable future.
Some of the growth in population of the
borough and township since 1950 can be
attributed to enrollment increases at Gettysburg
College and the Lutheran Seminary. These two
institutions, drawing students primarily from the
mid-Atlantic states, grew from 1,231 students in
1950 to 1,875 in 1970. The institutions' present
policy is to stabilize the size of the student body
at or near 2,000 students.
The growth of the borough, as we have
mentioned, has stabilized, with very few vacant
areas left undeveloped. New residential
buildings are spreading into Cumberland
E-30
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Township, Gettysburg's suburb. The population
is expected to remain constant between
7,000-7,500. The borough has enacted zoning
ordinances over the past four years, which
should help stabilize new construction and help
control and reduce the intrusions to the
adjoining military part and cemetery.
The borough is governed by a strong City
Council-weak mayor type of local government.
The voters elect nine lx>rough council
representatives and a functionary mayor. The
Borough Council appoints the planning
commission, an historic district review board, a
zoning hearing board, and other municipal
boards and authorities, as well as an
administrative city manager.
F. Borough Revenues and Economy
Visitors began coming to view the battlefield
at Gettysburg even before the end of the Civil
War. Relatives of the men who fought in the
pivotal battle made up a large portion of early
visitors. By the time.of the establishment of the
National park, in 1895, a tourist industry to
provide goods and services to the ever-
increasing number of visitors was well
underway. Tourism has grown to be the major
economic factor in Gettysburg and Cumberland
Township, and, thus, a significant county factor
as well.
The National Park Service and others
associated with or concerned about Gettysburg
often claim that the presence of a large and
important national battlefield in the area is,
because of the large number of tourists who visit
it, a boon and not a hindrance to the local
economy. While much of the hard data supports
this position, they do not take into account such
negative aspects as increased traffic congestion
and lack of parking, seasonal employment and
lower paying jobs, and the preemption of land
that could have been devoted to unrealized
industrial or residential development. The hard
economic data cannot measure the impact of the
park on the quality of life in the Gettysburg
area. Studies do reveal that in 1970* , about
$ 103,013 of Gettysburg's municipal revenues
were attributable to tourists, with an additional
$6,921 of real estate taxes paid indirectly by
tourists. This amounts to $ 109,934, or 30.6
percent of total revenues. Similarly, 33.5
percent of total revenues for Cumberland
Township are attributable to tourists.
As is the case with most local governments,
the Borough of Gettysburg finances municipal
expenditure principally through real estate taxes.
Approximately 50* percent of the borough's
revenue is derived from taxation of real estate,
even with a large portion of the borough's land
in non-taxable institutional and governmental
status. The other two principal revenue sources
are an amusement tax of 10 percent, levied
primarily on tourist-oriented commercial
facilities in the borough, and revenue from
parking meters, which again are aimed at the
non-borough resident. Both the amusement tax
and the parking fees provide about 15 percent
each of the borough's total revenues. Unlike
larger towns, Federal and State grants provide a
very small portion of Gettysburg's money—less
than three percent in 1970.
Two other economic factors related to
tourism in the Gettysburg area should be
mentioned. First, it has been estimated by the
Pennsylvania Department of Community Affairs
that tourists currently pump between 15.1 and
20.8 million dollars into the local economy
annually, and that this amount is multiplied two-
fold as the tourist dollars are respent. Second,
and a factor often overlooked, is the flow of
funds generated by the National Park Service
itself. Out of a fiscal 1975 budget of $985,900,
approximately $978,500 were spent locally.
About 83 percent of the park budget is payroll,
and an additional $ 100,000 are spent locally for
annual construction and rehabilitation projects.
The tourist industry is the most important
element in the Gettysburg employment segment
of the economy. Retail trade and personal
services, the two industries most directly
affected by tourism, comprise 28.5 percent of
Gettysburg's resident employment, with 19.6
percent of those in retail trade. Manufacturing
accounts for 17.7 percent, and educational
services for 17.5 percent of resident
employment.
Since 1975, the entire borough of Gettysburg
has been listed in the National Register of
Historic Places as an essential element of the
1863 battle area. The Gettysburg Battlefield
Historic District, distinct from the Gettysburg
National Military Park which is a separate
National Register entry, was nominated by the
Pennsylvania Historic Preservation Officer and
entered on the Register on March 19,1975. The
District contains 11,820 acres, including the
3,874 acres of the Gettysburg National Military
* All figures 1970: Source: A Study of the
Economic Impact of the Gettysburg National
Military Park and Tourism on the Gettysburg
Area; Pennsylvania Department of
Community Affairs, 1975.
E-31
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Park, and more fully encompasses a
geographical description of the 1863 battle that
began north of the barough, involved fighting in
the western half of the borough, and concluded
south of the borough.
Other properties in the borough that are listed
separately on the National Register are:
(I) The Adams County Courthouse at
Baltimore and W. Middle Streets;
<2) Pennsylvania Hall, on the campus of
Gettysburg College; and,
(3) Old Dorm, Lutheran Theological
Seminary, on the Seminary campus.
The previously mentioned 25-block
Gettysburg Historic District, designated for its
architectural significance and importance in the
original development of the borough, is not
separately listed in the National Register but is
included as part of the Gettysburg Battlefield
Historic District.
The borough has not initiated a survey of
historic structures and places. A survey is
underway, however, by the recently formed
Historic Gettysburg-Adams County, Inc. Using
volunteer helpers, the organization has surveyed
and photographed over 450 structures.
G. Cumberland Township
Population figures that were presented earlier
sharply reflect the trend, well underway, of
Cumberland Township serving as a suburb to the
Borough of Gettysburg, which it nearly
surrounds. The population of the township in
1880 stood at 1,512. By 1940, that figure had
only reached 1,787. Over the next 30 years,
however, the population of the township nearly
doubled to 3,497 in 1970, as Gettysburg "filled -
in", and the area conformed to the post-World
War II American pattern of suburban growth.
Cumberland Township is the jurisdiction
whose future development and pattern of
development will have the greatest direct effect
on the Gettysburg National Military Park and
the Eisenhower farm. There is an apparent
conflict between the past history of the township
and its entrenched traditions of independent
farming and a rural lifestyle and the growing
suburbanization of that area of the township
most influenced by the borough's overflow. The
objectives and the administration of Gettysburg
National Military Park and the Eisenhower farm
are caught in the middle of that conflict, a
conflict that has many precedents in post-World
War II America.
The voters of Cumberland Township elect a
three-member Board of Supervisors as their
governing body. The supervisors appoint
necessary municipal officers, authorities, and
commissions. The five-member planning
commission is one of the bodies appointed by
the Board of Supervisors.
Cumberland Township first attempted to
enact a zoning ordinance in the early 1960's,
which was dropped from consideration because
of widespread public disapproval. Reportedly,
many residents viewed the proposed ordinance
as principally benefitting the National Park
Service at the expense of private land owners.
Long-time residents of Cumberland Township,
many of whom are owners or associated with
large farms in the township, can be expected to
resist any hint of land use planning and legal
controls over the land. New home owners, many
of them recently arrived in the Gettysburg area
and living in a suburban relationship to
Gettysburg, are bringing and will continue to
bring demands for new services, roads, schools,
shopping areas, parks, and other facilities nearer
to the newly developing residential areas.
Discussion and demands for planning and land
use controls in such a situation are inevitable,
and are well underway in the township. The
Pennsylvania Department of Community
Affairs, through its Bureau of Planning, has tried
to foresee the problems and has worked with the
township government to draft a comprehensive
land use plan. If the plan is adopted, the Bureau
can be expected to suggest zoning controls to
help implement the plan. Resistance to the
comprehensive plan is developing, primarily
among large land owners who, so far, do not feel
threatened by development and wish to maintain
the existing legal controls over land use in the
township, which consist of simple regulations
governing subdivision requirements.
The National Park Service is looked upon
with suspicion by many elements within the
township and will be a continuing centerpiece of
the discussion over land use controls. The
Federal Government, through the National Park
Service, has ownership of 17.9 percent of
Cumberland Township land, or 3,785 acres.
Another 198 acres is held by the National Park
Foundation for expansion of the Eisenhower
farm. The resentment of residents to Federal
ownership can be traced to the 1895 Act
creating the national military park, and the
ensuing Supreme Court decision that upheld the
Federal Government's ability to employ the
power of eminent domain for park purposes. The
residents resisted that original action, and some
land owners in Cumberland Township have
resisted suggestions of park expansion over the
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ensuing 80 years. A major element in the
resistance to expansion, as well as a factor in
local antagonism toward the National Park
Service, has been the non-taxable nature of
Federal land. Local citizens and officials talk of
an "erosion" of the tax base.
H. Township Revenues and
Economy
The financial situation of Cumberland
Township reflects the unnatural economic
situation of a large nearby tourist-related
attraction, the Gettysburg National Military
Park, even more so than does the Borough of
Gettysburg. The Pennsylvania Department of
Community Affairs reported that in Cumberland
Township in 1970, $33,633 of municipal
revenues were the direct result of tourism, with
an additional $597 attributable to indirect real
estate taxes paid by tourists. This amounted to
$34,230 or 33.5 percent of total revenues. The
corresponding percentage of the Borough's
revenues was 30.6 percent.
The largest source of Township Revenue is
derived from amusement taxes, a seven-percent
levy placed on commercial enterprises that
cater to tourists drawn to Gettysburg because of
the Gettysburg National Military Park. Nearly
33 percent of total revenue is from the
amusement tax. Another 30 percent of
Cumberland's revenues is from real estate taxes.
The third primary source of revenue for the
township is through State highway aid derived
from the highway-user tax levied on gasoline -
related products by the State.
Cumberland Township is the jurisdiction that
feels the greatest impact of the tax exempt status
of the National Park Service lands in the
Gettysburg area. With 3,785 acres of the
Township in National Park Service or National
Park Foundation stewardship, this land
constitutes over 17 percent of the Township's
land area. Other tax exempt lands in the
Township, primarily school district land, county
government acreage, and church property,
account for only an additional 255 acres. While
this situation might appear to impose a severe
hardship on the township, documentation
produced by the State refutes any such claim.
The township has a relatively minor amount of
land in tax exempt status compared to other
jurisdictions. Hie total township tax exempt
acreage is 18.5 percent of total land, while the
Borough of Gettysburg, primarily because of the
College and Seminary has 36.6 percent of its
acreage in tax exempt status. Nine of 33
jurisdictions in Adams County, in fact, have a
higher percentage of land in a tax exempt status.
While no in-depth picture of the Gettysburg
economy has been presented, an interesting
conclusion of a 1975 study by the Pennsylvania
Department of Community Affairs, entitled A
Study of the Economic Impact of the Gettysburg
National Military Park and Tourism on the
Gettysburg Area, is of relevance to both the
economy of Cumberland Township and the
Borough of Gettysburg. The report commented
that:
The residents of Gettysburg and Cumberland
Township are understandably more oriented
toward the employment sectors related to
tourism. Although tourism and manufacturing
industries are not mutually exclusive, certain
other local factors (soil limitations, water
supply, sewage, etc.) mitigate against large-scale
industrial development. It seems evident that
despite the lower paying and seasonal jobs
associated with tourism, that the local economy
would be worse off, not better, without the
tourist dollars and jobs.
-------
Part 3
Planning in the Gettysburg
Area
A. Introduction
The bitter legal and emotional struggle that
surrounded the construction of a 307-foot
observation tower overlooking the Gettysburg
National Military Park ended with the building
of the tower. It is now the dominant element of
the Gettysburg landscape. The height and
metallic color of the tower intrude upon the
pastoral scene of rolling hills and farmland
surrounding the Borough of Gettysburg and its
low-rise scale, where church steeples and public
building cupolas formerly were the highest man-
made features. The presence of the tower is, in
large part, an excellent example of what can
easily occur when there is no legal control on
the use of the land.
The tower controversy, which reached a
climax in the courts in 1971-72, has led to
changes in the approach to problems in the
Gettysburg area and served as a stimulus to
those concerned about protection of the historic
identity of Gettysburg. At least two identifiable
and beneficial developments have occurred
since that period. First, the National Park
Service has taken significant steps to become a
part of the Gettysburg community, and there is
an easing of local animosity. Second, the three
principal local units of government, working
with the Commonwealth of Pennsylvania, have
begun to undertake comprehensive planning
and the first hesitant steps to initiate land use
controls.
The earlier total reluctance of the
municipalities to enact land use controls was the
subject of criticism by the court in the 1971
decision against the Commonwealth of
Pennsylvania's request for a permanent
injunction against the tower. The court had
criticized Adams County, Cumberland
Township, and the Borough of Gettysburg for not
previously attempting to remedy the excesses of
commercialism and intrusions to the historic
Gettysburg scene, and advised those opposed to
intrusion to insist that local officials enact
appropriate ordinances and adopt
comprehensive plans for the area. The recent
moves to undertake plans and control land use,
as we shall see, owe as much to the increased
speed of growth around Gettysburg, and the
reaction to that growth as it concerns the
protection of historic resources.
B. Land Use Control Background
The application of public powers to restrict
the use of privately owned land is a relatively
recent development. Most laws in America
before the twentieth century related only to
those uses considered a menace to life. Colonial
Boston's segregation of the storage place for
gunpowder from the center of the city was one of
America's first recorded acts of "zoning". The
development of zoning ordinances, the most
widely accepted and practiced formof land use
control, arose with the recognition of the
necessity for dealing with the problems created
by the concentration of people in cities. From
the migration to the cities and the unplanned
growth of these cities came zoning to help
regulate the uses made of land within city
boundaries. New York City enacted the first
comprehensive zoning ordinance in this country
in 1916. Enforcement of esthetic standards
through the zoning power followed in due
course and was supported by the courts.
Zoning is one of the most important means of
putting community plans into effect. The power
to zone is derived from the police power of the
State, a basic power reserved to the States by the
Constitution under their authority to protect the
public health, welfare, and safety. States have
generally vested the zoning power in counties,
towns, and cities, and left it up to these
jurisdictions to enact or not enact zoning. Most
States, including Pennsylvania, have enacted
enabling legislation to guide municipalities in
the specific use of the zoning power. The State
Enabling Act defines the scope of zoning,
procedures for adoption of a local ordinance,
the composition of the zoning board and its
powers and functions, and methods for
modifying the ordinance. Pennsylvania has
given the power to zone to its counties, but if a
municipality within a county, such as a borough
or township, enacts its own municipal zoning,
the municipality's ordinance becomes the
zoning law for the boundaries of that locality,
thereby superseding that of the county. Or, in
the absence of county zoning, which is the
situation in Adams County, a municipality can
enact zoning that will remain in effect even if
the county decides to enact county-wide zoning
at a later date.
It has been the history of zoning in America
that municipalities resort to zoning as a reaction
to growth. As long as an area remains essentially
rural with few concentrated areas of population,
control over the use of land for the common
welfare usually is not deemed necessary.
Typically when a village expands to a town and
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the boundaries of a town become
indistinguishable in the suburban pattern of
growth, then zoning and debate over what
particular land uses are desirable become issues.
The long-time residents, often farmers of
large tracts of land, feel threatened by
discussion of controls on their land. They are
joined by the more recently arrived commercial
interests and real estate speculators who have
benefited from the situation of growth and lack
of land use controls. The Gettysburg area
presents a current case study of this pattern. The
Gettysburg situation has the added ingredient of
the major Civil War battlefield as an element
and an issue over land use controls.
Zoning, it should be pointed out, is not a
substitute nor an alternative for a general plan,
sometimes termed a comprehensive plan, for a
community. The zoning ordinance and the
zoning map that delineates districts within
which provisions of the ordinance apply serve as
the legal instruments or tools to achieve basic
development policies and objectives set forth in
the general or comprehensive plan.
C. Previous and Current Planning in
Gettysburg Area
The Planning situation in and around
Gettysburg has evolved substantially since the
debate over the construction of the tower and
the original involvement of the Advisory
Council on Historic Preservation in 1972.
Comprehensive planning is underway in
Cumberland Township and the Borough of
Gettysburg has enacted zoning ordinances.
Planning and zoning are significant steps for
the local Gettysburg-area governments to take,
offering short-run protection for the Gettysburg
battlefield, the Gettysburg National Cemetery,
and the Eisenhower farm. Other adjoining
municipalities in Adams County, now more
rural in character, still reject any form of land
use controls. Some of the scenic areas in these
townships can be viewed from vantage points in
the battlefield and the Eisenhower farm. The
Adams County Planning Commission has
rejected county-wide zoning in the past and does
not foresee land use controls as acceptable to
most of the townships that surround Gettysburg.
Since 1972, the Borough of Gettysburg and
Cumberland Township, which contains
Gettysburg National Military Park and
functions as a suburb of the borough, have taken
commendable steps to develop land use controls
and attempt planning, which for the immediate
future will be beneficial to and supportive of the
objectives of the National Park Service. One
objective is to protect the historic and scenic
qualities of the original appearance of the
battlefield.
What led the borough and the township to
act? Two elements seem most significant. First,
the battle over the tower and the accompanying
involvement of local, State, and national
interests included a debate over the lack of and
desirability for land use controls, highlighted by
the court's reprimand to the localities for their
failure to exercise appropriate land use and
development controls. The reprimand served as
an instruction to act. Second, the Federal
Government and the Commonwealth of
Pennsylvania were already engaged in planning
efforts, and the tower controversey served to
intensify and strengthen these efforts. The
involvement of the State, through its
Department of Community Affairs, has been the
strongest and most influential part of the
planning efforts over the past five years.
While this investigation and report will
commend the planning efforts of the past five
years, a strong note of caution is added. The tool
being considered to enact planning in the
Gettysburg area is, predictably, zoning—zoning
of the most traditional kind. There are certain
inherent and unavoidable problems that will be
encountered in future years if local zoning is to
be the only form of protection Gettysburg
National Military Park, the National Cemetery,
and the Eisenhower farm are to have from
intrusions on the historic scene. These problems
will be associated with the following:
1. Local zoning is not static. The objective of
the local governments may change and easily
conflict with the objectives of protection of
Gettysburg National Military Park. The primary
revenue for Cumberland Township and a sizable
port ion for the Borough of Gettysburg is from
amusement taxes that are collected from private
recreational and museum-type attractions
relating to the 1863 battle and battlefield. The
pressure to accomodate more taxable enterprises
will probably continue to exist, although the
new Payment in Lieu of Taxes Act may
considerably reduce this pressure. These
enterprises will seek locations accessible to
tourists and park interpretive sites. It is a
recognizable and acceptable pract ice that local
governments often exercise the zoning power in a
way which will provide the highest taxable value
on property.
2. Zoning, by legal interpretation, must be
flexible and responsive. The regulation of
private land uses through zoning does not
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require a permanent establishment of
compatible uses. The exercise of the police
power in the interest of health, welfare, and
safety requires that there be an opportunity to
reevaluate and reconsider the various factors
affecting land usage. The opportunity will be
there, as it must be, for interested parties to
apply for changes in the uses zoning establishes.
3. Land use controls now being considered for
enactment in the Gettysburg area do not cover
all areas affecting Federal properties. From the
high vantage points along Cemetery Ridge, such
as the High Water Mark of the Confederacy and
the Round Tops, a visitor looking west and
southwest beyond the Confederate lines on the
second and third days of the battle sees a
landscape not too different from the I860's. The
land is in agricultural use, consisting of gently
rolling hills and meadows leading up to the
South Mountains, six to seven miles
westI southwest of cemetery ridge. While this
area is entirely in Adams County, the boundaries
of Cumberland Township extend only for about
two miles. Beyond lie unzoned Highland,
Freedom, and Liberty Townships and farther
west, where the visible South Mountains rise, is
Hamiltonban Township. (See map on page 13 J
Freedom Township also borders the Eisenhower
farm to the Southwest.
Similarly, the scenic views to the northwest of
Gettysburg, from which Confederate forces
approached on the first day of the battle, extend
into unzoned Franklin and Butler Townships.
The area adjoining Gettysburg National
Military Park to the east and northeast of
Gettysburg is of lesser concern visually because
of topographical protection, but constitutes yet
other unzoned jurisdictions, Straban and Mt. Joy
Townships. Straban and Cumberland Townships
are probable areas for industrial and commercial
growth connected with the principal
north! south route around Gettysburg, the Route
] 5 bypass.
Because of the condition of a sizable quadrant
of land unopen for development and occupied by
one use, i.e., Federal parks, growth of the
Gettysburg area will be forced to funnel
unnaturally into corridors, north, east, and west,
which are open for expansion. These growth
areas can be expected to expand outwardly more
rapidly than they would if the park was not
abutting Gettysburg and forming a non-growth
quadrant to the south. The expansion of
residential and service areas will reach unzoned
areas more rapidly than if National Park Service
land did not form a southern "no growth"
barrier.
4. Park redevelopment plans will alter the
existing patterns of land use. A major element of
the unpublished Master plan for Gettysburg
National Military Park is a new visitor
orientation and contact center north of
Gettysburg. One of the purposes of locat ing the
new facility in that area is to draw automobiles
and congestion away from the Cemetery Ridge
road and National Cemetery areas near the
present visitor center, as well as to provide a
much needed improvement in the interpretation
of the three-day battle. However, the move
portends major redirection of land uses
associated with commercial services and
entertainment, which if allowed, can be expected
to follow the move.
The Borough of Gettysburg hopes to prevent a
repetition of the intrusions that have occured in
the battlefield area near the existing visitor
center and cyclorama. The borough and
hopefully the township will have their zoning
ordinances in hand, but problems associated
with zoning and planning will assuredly arise.
One problem will be the previously discussed
pressure to increase local tax bases by
accomodating tax-generating establishments. A
major problem that is presently much discussed
is that all plans, including the handling of traffic
by the National Park Service, Cumberland
Township future land use direction, and
vehicular congestion in the Borough of
Gettysburg, are tied to the construction of a long
proposed eastI west Route 30 bypass north of
Gettysburg. Without the bypass, all parties see
chaos resulting if the visitor center is relocated.
The investigations that were part of this report
revealed that construction of the bypass is not
probable in the foreseeable future if highway
funding possibilities remain as they are. The
State has assigned a low priority to the project,
principally because of the high cost of the road.
The Pennsylvania Department of
Transportation estimates its share of the project
under existing State-Federal programs (Route 30
is a U.S. highway) to be between 25 and 30
million dollars. The most recent State allocation
plan for major highway projects in Adams
County lists only $8 million over the next twelve
years for all of Adams County.
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D. Planning That Has Occurred to
Date
The fight over the tower and the surrounding
publicity and interest by the State and Federal
agencies can be said to have helped lead to
zoning ordinances in the Borough of Gettysburg
and the possible adoption of a comprehensive
plan and perhaps zoning ordinances in
Cumberland Township. Planning for the area
had already begun, however, by the time the
tower controversy reached a climax in late 1971
and early 1972.
In 1970 Adams County received an urban
planning grant from the Department of Housing
and Urban Development under provision of
Section 701 of the Housing Act of 1954, as
amended, for preparation of a county-wide
comprehensive plan. Administration for the
preparation of the report rested partly with the
Bureau of Planning, Pennsylvania Department
of Community Affairs. The Adams County
Comprehensive Plan, published in three
volumes in early 1971, was the first major
planning document produced for the locality.
As such, it compiled for the first time much
valuable data on economic and population
trends, natural resources, transportation needs,
existing land use patterns, and community
facilities. The study also contained
recommendations to guide the future
development of the county.
The Adams County plan is general in nature,
with no proposals to enforce its provisions. It is
seen by county officials as a general blueprint to
encourage the many and varied municipalities in
the county, as well as private enterprise, into
making decisions based on firm data and
hopefully for county-wide benefit.
Nineteen seventy-two saw the publication of a
unique planning document entitled The
Gettysburg-Cumberland Demonstration
Program. It was the product of a combined effort
by the National Park Service, the Borough of
Gettysburg, and Cumberland Township to
produce a prototype program for cooperation
between the Federal agency and the adjoining
local governments. The genesis for this effort
was the increasing concern by the Department
of the Interior and other Federal bodies during
the 1960's concerning types of development
occuring in and around national parks
throughout the country. One result of this
concern was the announcement by the U.S.
Department of Housing and Urban
Development that it would fund, under a
Section 701 planning grant, a demonstration
E-
study to develop an experimental planning
process that could be followed by both the
Federal government and local municipalities in
areas where major national parks exist. After a
lengthy selection process and consideration of
many park areas, officials chose Gettysburg
National Military Park and surrounding
municipalities as the pilot. The growing tower
controversy may have influenced the decision.
The noted planning consulting firm of
Wallace, McHarg, Roberts, and Todd and
Gladstone Associates was chosen to undertake
the study and prepare a demonstration report.
The Wallace/ McHarg firm is widely-respected
for its work in environmental planning, and its
resulting document presented an extremely
useful description of where particular types of
growth should occur, based on an impressive
environmental analysis of Cumberland
Township and the surrounding region.
The report further outlined a sophisticated
planning process that was experimental in its
recommendations for involvement of a Federal
agency, the National Park Service, in the
decisions of local government. Among the
recommendations in the report were the
following:
1. The Borough of Gettysburg, Cumberland
Township, and the National Park Service should
form a joint planning commission.
2. The Borough, Township, and the National
Park Service should form a quasi-public
development corporation to provide legal,
planning, design, and managerial skills to the
communities; to acquire and improve suitable
lands; and, where appropriate, to develop the
lands or convey them to private entrepreneurs
for appropriate and desired uses.
3. The Borough, Township, and the National
Park Service should form an Advisory Board to
begin implementation of recommendations in
the demonstration plan, carry on the planning
work, begin legislative tasks, and coordinate
between citizen groups and levels of
government.
No one addressed the legality of these steps in
the absence of new Federal and I or State
legislation. The legal question remained
unanswered because the recommended planning
process was, understandably, never initiated.
The recommendations would have been strong
stuff for the most advanced American
community and were difficult to accept in a
community which had no prior history of
planning. At that time, there was not even the
simplest zoning ordinance on the books, and,
then as now, neither the borough nor the
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township employed a professional planner.
A further barrier for any success of the
demonstration program was the expectation of
the local communities concerning the study.
The Wallace/ McHarg firm apparently entered
the project with the idea of producing a
recommended experimental program from
which a comprehensive plan would later
emerge. The local municipalities were
apparently expecting a "Plan" in the traditional
concept to lead the local governments in
implementation of concrete objectives. The
National Park Service, for its part, was
proceeding with preparation of its own master
plan (still not completed) independent of the
local governments and of the Wallace/ McHarg
study. No party appeared to be willing to lead in
establishment of a demonstration process, and
the end result was dissatisfaction by all
concerned.
The Wallace/ McHarg study certainly
understood the "Gettysburg Problem." It is the
same problem that today is more pressing than
ever. The introduction of the 1972 study stated
the complexities that National Park Service and
the local communities faced:
The long slow growth patterns both in the
local community and in visitor attendance to the
Park have in the past provided time to adjust to
change. The forces are now at hand which will
alter both the form and the pace of development.
Anticipated growth in attendance at the
Gettysburg National Military Park, National
Cemetery and Eisenhower National Historic Site
will create pressure for additional facilities both
within the Park System and from commercial
activities which serve the visitor. Cumberland
Township is in the throes of changing from an
agricultural region to a suburb of the Borough
and a target of speculative ventures generated by
increasing tourism. The Borough itself has
reached a point of limited possible future growth
and increased competition for development from
adjacent areas. With pressures of these
dimensions, the potential for sharp conflict and
eventual paralysis arising from high levels of
dissent between the three communities is ripe.
Despite dissatisfaction, the 1972
Demonstration project did leave a beneficial
legacy. Communication improved. The
Wallace/ McHarg report recommended
formation of a three-party advisory board to
carry on planning that was to initiate with the
report. A short-lived advisory board, with
borough, township and National Park Service
participation, was formed to discuss common
problems and serve as a means of
communicating the objectives and content of
each member's plans. The advisory board
disolved in disagreement over the purchase of
land by the National Park Service north of
Gettysburg, reportedly for a future relocated
visitor center. The advisory board was replaced
by a community relations committee, which still
serves as a means of communication between
National Park Service, local governments, and
citizen groups. All parties agree that
cooperation and communication between
National Park Service and local governments
has improved since 1972.
An additional contribution of the
Wallace/ McHarg study, according to most
reports, is that it "got things moving" and
motivated people to think of planning. What has
resulted so far, however, is not the sophisticated
process that was recommended. Instead, a very
traditional planning mechanism is being set in
place, bringing to the Gettysburg community
concepts of land use controls and laws to back
the concepts that had not been there before. In
retrospect, it would seem the natural place to
begin a local planning process.
The motivation first took the form of the
Borough of Gettysburg askind the Pennsylvania
Department of Community Affairs in Harrisburg
through its Bureau of Planning to help draw up
local zoning ordinances. This initiation was
encouraged by the State. Later, Cumberland
Township asked the same State agency to assist
in preparation of a comprehensive plan for the
township. The State's Bureau of Planning has
acted as a competent professional staff for the
two local planning commissions. It is a
beneficial situation in that the planning for both
municipalities, which are contiguous, has been
or is being done by the same staff. (An example
of the benefit thus derived is that the height
limitation on new construction is 35 feet in the
Borough ordinance, and it is assumed if zoning is
proposed those will the same height controls for
the township.)
E. Borough Ordinances
The enactment of current borough ordinances
is the result of four years of effort on the part of
Gettysburg's five-menber planning commission,
using the consulting services of the
Pennsylvania Department of Community
Affairs. Instead of attempting to prepare a
comprehensive plan as a first step, a task that
could take years, the commission decided to
proceed directly with zoning in order to
stabilize the borough's building activities and
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control the proliferation of signs and billboards.
The comprehensive plan is still in the discussion
stage.
Current planning controls are in three forms:
1. Historic District Ordinance The borough
first enacted an historic district ordinance
covering a 25-square block area centered around
the Lincoln Square. The original county
courthouse stood near the square many years
ago, and it is still the hub of borough activity
because all principal roads into and out of the
community meet there.
The historic district ordinance, adopted in
1972, was permissible under a 1961 Act of the
Pennsylvania legislature, which allowed historic
district zoning combined with the establishment
of an architectural review board. In Gettysburg,
the historic district review board recommends to
the Borough Council the approval or
disapproval, with or without suggestions, of
applications for work on the exterior of buildings
within the central 25-block area. The council
has almost always accepted the
recommendations of the review board.
2. Sign Ordinance In late 1973, the Borough
Council approved a sign ordinance in reaction to
the growing number of large and brightly
colored commercial signs and billboards placed
on major thoroughfares near the Gettysburg
National Military Park and the National
Cemetery. The ordinance prohibits the erection
or alteration of any sign until the building
inspector for the tx>rough issues a permit.
Existing or proposed signs withn the Borough
historic district are subject to the additional
approval by the historic district review board.
The ordinance requires that an owner limit
signing to his premises, and that advertising
must relate to the activity on that particular
property. It also limits the size of signs to one
square foot for each lineal foot of property street
frontage, and in no case allows a sign to exceed
50 square feet. Animated, flashing, or moving
signs are prohibited. The ordinance contained a
"grandfather clause, "permitting signs not in
conformance with it at the time of enactment to
be exempt for a five year period or until
November 14, 1978.
3. General Zoning Ordinance In 1975, the
Borough Planning Commission, working with
the Bureau of Planning of the Pennsylvania
Department of Community Affairs, developed a
general zoning ordinance that was adopted by
the Borough Council and became effective in
October, 1975.
The general zoning ordinance for Gettysburg
contains a "Statement of Community
Development Objectives," which, until a
comprehensive plan is adopted, will serve as the
borough's planning goals. The statement defines
the physical aspects of the land, the natural
resources, and the historic properties that as a
fundamental consideration are most worthy of
protection. According to the document,
"development should take place in the proper
areas so that in no way does it react negatively
with out prime natural resources."
The "Statement of Objectives" calls for
complete cooperation with and by the National
Park Service, the adjoining Cumberland and
Straban Townships, and the Gettysburg College
and Lutheran Seminary. The stimulation of
commercial development within the Borough is
a primary objective, including the
encouragement of the conversion of the
downtown core into a "unique Civil War Period
Shopping Mall."
The borough zoning ordinance and zoning
map are essentially protective of the integrity of
the Gettysburg National Military Park and the
National Cemetery. Generally, a 35 or 40-foot,
or three-story, height limitation is placed on
construction—with spires, belfries, cupolas,
chimneys, and other appurtenances usually
located above the roof of a structure allowed to
exceed that height. Institutional buildings (the
institutional zones, being primarily concerned
with the College and Seminary on the western
side of town) are allowed a height of eight
stories.
The zoning ordinance essentially defines the
existing pattern of land use in the borough and
attempts to reinforce and encourage that pattern
with controls. The ordinance is administered by
the building inspector for the borough. A zoning
hearing board, appointed by the Borough
Council, oversees the ordinance and hears
appeals of decisions made by the building
inspector and considers requests for zoning
variances and special exceptions. One of three
members of the zoning hearing board, but not
more than one, is usually a member of the
borough planning commission.
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F. Cumberland Township
Comprehensive Plan
The State Bureau of Planning, after assisting
the Borough of Gettysburg in the role of
consulting staff in the preparation of borough
zoning ordinances, agreed to help the
Cumberland Township Planning Commission
draft a comprehensive plan. The plan, now in
draft, is, as are most plans that attempt to serve
varying interests, a compromise between large
landholders, commercial interests, real estate
development interests, those favoring
protection of the Federal historic areas, and
those favoring growth and expansion of the tax
base. A fair appraisal would be that the
Gettysburg National Military Park and the
Eisenhower farm receive sympathetic treatment
in the plan, if not foremost consideration.
If the plan is adopted and if permanent legal
controls follow, then the integrity of park land
would be fairly well served by Cumberland
Township. However', even if the township
adopted the plan and enacted controls, a not
altogether certain expectation, the probability
will remain for modification and adjustment to
accommodate any developing growth situation
in the township.
The draft of the comprehensive plan
"protects" or is sympathetic to the need for the
protection of Gettysburg National Military Park
and the Eisenhower farm in that its land use
proposals reinforce existing patterns of
township growth. That pattern has been for
residential development to occur northwest of
the Gettysburg National Military Park;
consequently the areas visually more critical to
maintaining the National Park Service objective
of a rural setting—those being the views from
the second and third days of the battle—have
remained essentially agricultural. The plan's
authors, however, foresee an eventual zoning
ordinance that will allow large-lot (one or two
housing units per acre) residential development
as township population grows in an agricultural
zone directly west and southwest of the
Seminary Ridge section of the military park.
Areas to the south and east of the park that
border Cumberland Township receive the
protection of a conservation zone under the
draft plan. These areas are now fairly well
protected by hills and natural vegetation.
Even if Cumberland Township adopts a
comprehensive plan and a zoning ordinance to
implement it, the most immediate problem of
visual protection for the Gettysburg National
Military Park will be in the area of existing
residential development northeast of Gettysburg
and just west of the Peace Light Memorial and
adjacent park land associated with the first day
of the battle. Residential development should
continue in this area at an increased pace, with
or without a comprehensive plan, as a result of
planned expansion of the township sewer
system. Natural vegetation in this area is thin
and the vista is open, although interrupted by a
few rolling hills to a row of small mountains
about three miles away. A building height
limitation would be helpful in this area, if a
zoning ordinance materialized, as would
refinement of the plan and any zoning proposals,
to encourage residential developments into the
valleys between the rolling hills and onto the far
or western side of the hills.
The potential problem of intrusions to the
Gettysburg National Military Park and
Eisenhower Farm through construction of high
structures of any nature will exist in all areas of
Cumberland Township in the absence of a local
zoning ordinance limiting structural heights or
in the absence of unique State or Federal action.
If a comprehensive plan is adopted, it is hoped
that a zoning ordinance will follow that includes
a universal height limitation on new
construction throughout the township.
Perhaps the greatest potential problem of
intrusion for Gettysburg National Military Park
can be identified as building or development in
that part of Cumberland Township just beyond
the western and southwestern borders of existing
park boundaries. This area is readily visible
from important vantage points on Cemetery
Ridge, and certain kinds of development would
conflict with the scene of a rural landscape that
the National Park Service is working to preserve
in and around the battlefield and the farm. If
there are not unique State and/ or Federal
actions in this area, there are three possibilities
to consider.
First, the area will continue to develop
without any form of new land use controls.
Presently, with the exception of easily met
subdivision regulations, there are no controls on
this or other parts of Cumberland Township.
This area, lying just beyond Seminary Ridge, is
now in farm usage and borders on residential
areas to the north swiftly reaching out from
Gettysburg. With the rapid growth of the
township, which has doubled in population since
1940, this area can shortly be expected to
undergo pressure for residential subdivision. If
tourism continues to grow, this area will be
attractive for new tourist-related industries,
although access to major roads is presently
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Legend
Residential
^ Agricultural
^ Conservation
Historic
£ Limited Industrial
Institutional
| Commercial
A
N
i—i—i—i—i
0 1/2 I t 1/2 2
Scale in Miles
E-41
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absent. If the existing tower becomes a financial
success and someone wishes to try and duplicate
it, no other location in or around Gettysburg
will afford a more advantageous vantage point
to the Gettysburg National Military Park and
the Eisenhower farm.
The situation would be different if the
township were to adopt the comprehensive plan
and zoning controls. Then the area would have
locally imposed legal restraints placed on its
use. A zoning ordinance based on the plan could
be expected to encourage continued agricultural
use, but would permit a large-lot residential
development if the demand for it increased. A
building height limitation could be expected
based on the plan that has been drafted.
Finally, it has been pointed out that any
zoning ordinance must legally be responsive to
requests for adjustments. If growth continues,
this area of the township at some future date,
probably in 10 to 20 years, could be under
pressure to rezone to a small-lot residential area
with needed commercial services to follow. The
possibility will also exist that a plan or zoning
ordinance, if it proves unpopular, will be
changed by elected officials in response to
public demand.
In summary, Cumberland Township is
presently in a hesitant and transitional period
from no prior planning to adopting its first
comprehensive plan. A zoning ordinance of a
traditional and simple nature would be the next
logical step. Some resistance to land use
controls is evident among land owners in the
township, lessening full optimism about the
quick adoption of even a simple zoning
ordinance. The draft of the comprehensive plan
respects the integrity of the Gettysburg National
Military Park in that it proposes to maintain the
status quo of existing patterns of development.
Plans and zoning in rural areas undergoing
suburbanization are traditionally open to
change and fairly quick revision as growth
accelerates. It should also be remembered that
Cumberland Township's move to land use
controls will not directly affect adjoining
townships, some parts of which are visible from
the Gettysburg National Military Park and the
Eisenhower farm.
The evidence of planning that is beginning to
occur in an around Gettysburg, while long
overdue, is a good sign. It is proof that local
officials and citizens are aware of a problem and
have begun to act. However, it can not be said
that there is an awareness of the need for
extraordinary protection for the unique
environment of the Nation's most significant
battlefield. The planning that is occuring differs
little if at all from what a locality of similar size
and make up would adopt in America today
without a Gettysburg National Military Park in
its background. Furthermore, the ongoing local
planning does not include the concept of the
battle area as the entire Gettysburg Battle
Historic District, as included on the National
Register of Historic Places. The Register
district is three times the land area of the
existing Gettysburg National Military Park,
including most of the Borough of Gettysburg.
Considering protection of the historic scene in
perpetuity as of paramount concern, one can
look upon recent planning and zonning
activities as buying time. Historic preservation
planning should look at protection of
worthwhile properties and areas from a very
long perspective. Even with the recent local
planning activity, it would appear doubtful that
the area surrounding historic ground will
receive the land use protection it needs to meet
historic preservation goals. If special and unique
protection is not provided, the area can be
expected to change and intrusions will continue
to occur.
One might view the problem in terms of an
assignment of priorities. Is the Gettysburg scene
worthy of protection in a rural setting similar to
1863? The historian and historic preservationist
might answer that if the country is to
commemorate a battle and a place to represent
and interpret the American Civil War, the
Gettysburg should be that place and that
battlefield. If the priority for protection is
assigned, then the conclusion is that existing and
now contemplated local land use controls will
be inadequate and special action will be
required.
G. Historic Gettysburg-Adams
County, Inc.
Formed in 1975, the Historic Gettysburg-
Adams County, Inc., is a non-profit organization
dedicated to the restoration and preservation of
historical resources in the Gettysburg area.
Under its Articles of Incorporation, filed with
the Pennsylvania Department of State, its
purposes are "To foster and participate in the
preservation, interpretation, and welfare of this
historic, architectural, scenic and culturally
significant areas, districts, sites, structures,
objects and activities, and the townscapes and
lanscapes of the Borough of Gettysburg and
Adams County, Pennsylvania, and of the
Gettysburg National Military Park, Gettysburg
E-42
-------
National Cemetery, and the Eisenhower
National Historic Site, and to encourage their
appreciation by the general public." The
organization is guided by a 21-member Board of
Directors and four elected officers. The daily
affairs of the organization are administered by a
salaried executive director and small staff, some
of whom are volunteers. Its small budget is made
possible by membership dues, donations from
the borough, and grants from the National
Endowment for the Arts, among others.
During its short life, the organization has done
much to promote historic awareness in the
Gettysburg community and to encourage the
preservation of buildings in the borough's
historic district, particularly by providing free
technical assistance to those owners
undertaking rehabilitation and restoration.
Historic Gettysburg-Adams County, Inc., has
developed a 13-year "Bicentennial Era
Restoration Project" for Gettysburg Historic
District, which if implemented will do much to
upgrade the borough's historic resources. Plans
call for the preservation of the historic exteriors
of buildings, of traffic from the historic district,
the installation of stone and brick sidewalks and
curbs, plantings and landscaping and Victorian
street lighting, relocation of utility lines
underground, introduction of more compatible
street furniture, and more appropriate
commercial, street, and traffic signing. It should
be emphasized that the effort is aimed at
persuading the jurisdictions and individual
owners to undertake proposed improvements
and to assist in securing what Federal funds that
mieht be available for these purposes.
E-43
-------
Bibliography
Advisory Council on Historic Preservation,
"Chronology of Significant Events, National
Gettysburg Battlefield Tower, Inc.. " ACHP
Collections, Gettysburg File.
Andrew Brown, Geology and the Gettysburg
Campaign; U. S. Geological Survey,
Washington, D.C., 1973.
Bradsley, H.C., History of Cumberland and
Adams Counties, Pennsylvania. Warren Beers
and Company: Chicago 1886.
Borough of Gettysburg, "Gettysburg Borough
Sign Ordinance." Gettysburg Borough Council:
Gettysburg, Pennsylvania, 1973.
Borough of Gettysburg, "The Gettysburg
Borough Zoning Ordinance" (revised).
Gettysburg Borough Council: Gettysburg,
Pennsylvania, 1975.
Catton, Bruce, Gettysburg: The Final Fury.
Bekley Publishing Corporation: New York,
1974.
Clifton E. Rodgers and Associates,/!
Comprehensive Plan: Adams County, Parts 1,2,3
and Summary. Adams County Planning
Commission: Gettysburg, Pennsylvania, 1971.
Coddington, Edwin B. The Gettysburg
Campaign: A Study in Command. New York:
Scribners, 1968.
Haskell, Elizabeth, "New Directions in State
Environmental Planning." Journal of the
American Institute of Planners, Vol. 37, No. 4,
July 1971,pp.253-258.
McGrath, Dorn C., Jr., A Proposed Observation
Tower Overlooking the Gettysburg National
Military Park: Report to the Advisory Council
on Historic Preservation. Advisory Council on
Historic Preservation, April 1972.
National Park Service, "Development of
Eisenhower National Historic Site, H. J. RES.
81,91st Congress - 1st Session." Gettysburg
National Military Park, 1969. GNMP
Collections
National Park Service, "Gettysburg National
Military Park Master Plan," draft, September,
1976. GNMP Collections
National Park Service, "Log of Events Re to
Park& Regional Planning and Tower
Controversy at Gettysburg National Military
Park, Gettysburg National Cemetery,
Eisenhower National Historic Site." July, 1976.
GNMP Collections
National Register of Historic Places Inventory
Form - Nomination Form, "Gettysburg
Battlefield Historic District," March 19, 1975.
Files ofthe National Register of Historic
Places, 1100 L St., NW., Washington, D.C.
Northern Virginia Regional Planning and
Economic Development Commission, "Open
Space Easements in the National Capital
Region." Northern Virginia Regional Planning
and Economic Development Commission:
Fairfax, Virginia, 1965.
Overview Corporation, How to Implement
Open Space Plans: For the San Francisco Bay
Area, Volume I. Association of Bay Area
Governments: Berkeley California, 1973.
Oyler, John S., Pickett Charges; Everyone Else
Pays (The Story of the Gettysburg Tower
Controversy). Princeton University: Princeton,
New Jersey, 1972.
Pennsylvania Department of Community
Affairs, Bureau of Planning, Comprehensive
Plan: Cumberland Township, draft. Cumberland
Township Board of Supervisors: Gettysburg,
Pennsylvania, 1976.
Plimpton, Oakes A., "Conservation Easements:
Legal Analysis of Conservation Easements as a
Method of Privately Conserving and Preserving
Land." The Nature Conservancy: Washington,
DC.
Roy Mann Associates, Inc., People and the
Sound: Shoreline Appearance and Design.
National Park Service and New England River
Basins Commission: Cambridge, Massachusetts,
1975.
Regional Science Research Institute, Untaxing
of Open Space: An Evaluation ofthe
Effectiveness of Differential Assessment of
Farms and Open Space (A Council on
Environmental Land Use Publication).
Government Printing Office: Washington, D.C.,
1976.
E-44
-------
Storrick, W.C. The Battle of Gettysburg, 28th
ed. The McFarland Company: Harrisburg,
Pennsylvania, 1975.
Tilberg, Frederick Gettysburg National
Military Park, Pennsylvania, rev. ed., (National
Park Service Historical Handbook Series No.
9). Government Printing Office: Washington,
D.C., 1962.
Vanderslice, John M., Gettysburg Then and
Now. New York: G.W. Dillingham Company,
1899.
Wallace, McHarg, Roberts and Todd and
Gladstone Associates, Gettysburg - Cumberland
Demonstration Program. Pennsylvania
Department of Community Affairs: Harrisburg,
Pennsylvania, 1972.
E-45
-------
Acknowledgment
This report was prepared under the direction
of John D. McDermott, Director of the Office of
Review and Compliance, Advisory Council on
Historic Preservation. Mr. Ernest Holz of the
Council compliance staff gathered much of the
data on land use controls and is mainly
responsible for Parts II and III of the Appendix.
Dr. Harry W. Pfanz, Chief Historian of the
National Park Service, provided much of the
material that appears in Part I of the Appendix.
Mr. Dorn C. McGrath, Jr., Director of the
Department of Urban and Regional Planning,
George Washington University, provided
information on the preservation of historic
views and control of helicopter flights and
offered general guidance and advice on all
aspects of the study.
Others providing information used in the
study were Superintendent John R. Earnst and
Thomas J. Harrison, Chief of Resource
Management, Gettysburg National Military
Park; Mr. Charles P. Raynor, Office of the
Solicitor, Department of the Interior; Mr. Bruce
Hearn and staff, Bureau of Planning,
Pennsylvania Department of Community
Affairs; Mr. Andrew Larson, Planning Director,
Borough of Gettysburg; Mr. George Lambert,
Planning Director, Cumberland Township; Mr.
John T. Kallenbach, County Planner, Adams
County; and Mr. Ed Weintraub, Executive
Director, Historic Gettysburg-Adams County,
Inc.
While many contributed information, the
viewpoints and recommendations of the report
are those decided upon by the Advisory Council
on Historic Preservation. The report was made
possible by funds made available by the Council
and the National Park Service.
E-46
-------
APPENDIX F
Engineering Cost Information
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ExiSrring ®6bt <3bt'i 'V/ti 9/rf (f0r YSar")
Pn/it/al O^otinj + fWa« ntpfl a«cC Ccftf
Total '985* Local Cost
* Cq pi-Tor I Recoy/erf Factor- 9c ,T-
C$X iooo)
9.0
lHi(e
S(*
-------
f'HOJFCT NO.
CLIENT ,
5*?l-_4
^UBJtCT-
OF
WAPORA. Inc.
Environm«ntal/En«ryy/Economic Studies
*,re ^C^/Re^icnai
SHFFT *~7 OF ^
PREPARED BY _
DATE 5~ - 2-~-4/
CHECKED BY
DATE . -
EstimArEiD 1955" User Charges
Olunicipflli-ry: L_«-vce He<>.aAfct"
Ni/rnbdV o^* EDl/s: Z<*~2>' *¦ ^
(^4-fh QuoW 1979 0 x |oo©;
Cc\p\-re\{
F-eJfrol
Sbar€
t-oGql
She»r€
Ann *Jcx 1
O ~ m
Oo-Si-t-e 5y^ferrt$
Sewer
Xnel'.giWe
IS^to fftJ.
85^o
x/x tfeJuct-ion
\ \ ***i> 8
3| Co6*t")
EaiSt;^ Ocbt Ger*r^tnerrf (p0r Vlfiac)
flnnv/al Ope^or/og ~ fn«»nTPna*ce C©StT ('flwwil ©~m)
"Total 1985" Local Cost
* Cqpitt»l Recover^ Fa civ*"- 90^4^5,1^^
($x 1000)
SB 0£, ft
S, l"S.*
_ ^.o
2.0fr.1
Esnmrtrep |?05 USFR cMrtRae (1%?lf.l£pXC°*r) ^ ~ *s<"6
F"12
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