POSITION PAPER. Mare Island Naval Cemetery Grave Marker Removal and Replacement Incident

POSITION PAPER Mare Island Naval Cemetery Grave Marker Removal and Replacement Incident I. INTRODUCTION A. Overview Presented here is a description of recent actions carried out affecting at least seven historic grave marker artifacts located within the Mare Island Naval Cemetery, a major contributing resource to a National Historic Landmark (NHL) within a National Historic District Boundary in Vallejo, California. These artifacts collectively reflect significant events and sacrifices by naval personnel and civilians and comprise the first and oldest United States naval cemetery on the West Coast. This position paper is written on behalf of the Mare Island Heritage Trust, the interim manager of the Mare Island Shoreline Heritage Preserve where the Mare Island Naval Cemetery is situated. The Mare Island Naval Cemetery was established in 1858 with the first burial occurring in 1856. Between 1858 and 1921 when the cemetery was officially closed there were 922 burials there. The 2.43 acre tree enshrouded site sits on a gradually rising hill looking east over the Napa River or Mare Island Strait. Numerous significant and historic individuals and events are memorialized within these consecrated grounds including Anna Key Turner, daughter of Frances Scott Key, decorated service personnel as well as sailors from many other nations and victims of tragic events related to these military activities. B. Historic Status of Resource The Mare Island Historic District in Vallejo California encompasses approximately an area of 980 acres that contains buildings, structures and sites relating to military/ industrial/architectural/archeological and cultural history as associated with the period of significance, 1854 to 1945. Select portions of the Mare Island Historic District were designated as National Historic Landmarks on May 15 th, 1975 the 1858 Naval Cemetery being one of those selected properties. This designation resulted from the 1

determination by the Federal government that this historic property was of national historic significance. These landmarks (NHLs) are places where significant historic events took place, where prominent Americans worked and lived, that represent those ideas that shaped the nation, that provide important information about the past, or are outstanding examples of design and construction. 1 An added sense of urgency comes with the present status of the Mare Island Historic landmark in that since 1998 it has been designated as a Priority 1 threatened historic resource area and listed as threatened since the year 2004. The rationale for this category of listing is cited as: Threatened (Priority 1) indicates NHLs that have suffered, or are in imminent danger of, a severe loss of integrity. 2 C. City of Vallejo Review Procedures Addressing Requests for the Alteration to Historic Properties In recognition of the historic legacy of Mare Island and other resource areas and in compliance with requirements of the Certified Local Government Program of the U. S. National Park Service, the City of Vallejo (City) has adopted the Secretary of Interior Guidelines for Historic Resources as the standard for its Architectural Heritage and Historic Preservation Ordinance." As a part of this ordinance the City has identified a protocol for addressing initiatives (projects) that involve the alteration or related impacts on historic properties and resources within its jurisdiction. Its purpose is broadly stated: It is found that protection, enhancement, perpetuation and, use of buildings, structures, landscaping, districts and neighborhoods of historic, architectural and engineering significance located within the city are of cultural, aesthetic and economic benefit to the community and region. It is further found that the economic, cultural and aesthetic standing of the city will be enhanced by preserving the heritage of the city. The historic resources ordinance prescribes a review process as spelled out in Sections 16.38.220 through 330 Certificate of Appropriateness of the City Zoning Ordinance. Initially this position paper was structured to address the nature of this project, the referenced action and remedies with regards to this certification process and the possible options the review process allows. However, as important as this City-based review process may be, this paper is also intended to look at this incident from a broader viewpoint and address a larger question regarding how to protect and to allow public benefit of our most precious historic resources especially when they are located on existing public property. We wish to first characterize the details of the incident in a description of the actions taken and then their consequences. We then provide a brief narrative of the significance of the resources that were affected and then we lay out a course of steps that we believe are essential to address the immediate needs resulting from the action and then finally additional measures that are suggested as a template for both ensuring a greater level of 1 Mare Island Historic District Design Guidelines 2 National Historic Landmarks website: http://tps.cr.nps.gov/nhl/ 2

protection for these historical resources that reflect our heritage as well as perhaps encouraging greater public knowledge of their meaning and importance. 3

II. DETAILS OF THE INCIDENT Exhibit 1 It is our position there are two aspects of what transpired at the Mare Island Naval Cemetery that need to be discussed as separate considerations: First, the action itself that unfortunately occurred without approval, permit or notice on public property that is both a designated National Historic Landmark and within the City limits of Vallejo. Secondly, the aftereffects of the action involving the removal of existing grave markers and their replacements with new ones a. The Action During the week of August 23rd, 2010 without permit or prior City plan review, existing historic artifacts at the Mare Island Naval Cemetery were jack-hammered from their location, some damaged in the process as evidenced by remnant pieces (shards) of marble and concrete with soil scattered throughout the vicinity as well as foundational concrete pieces strewn around the base of two nearby trees. As shown in Exhibit 1, there were three relatively unscathed markers removed. There are also the remnants of portions of the other three removed markers shown in this exhibit. These gravestones mark the burial site of six Russian sailors who died in California while serving the Russian Navy and at least some of whom died while assisting US interests during the Civil War conflict period of 1861 to 1865. The concrete foundations and marble bases are those of the original stones those that were placed in the 1863 timeframe possibly by the Russian themselves and later broken due to vandalism or wear and tear (Exhibit 2). To the best of our knowledge there was no licensed archeologist present during this action nor was an archeologist, landscape or cultural resource specialist consulted prior to the action taking place. In the process of jack-hammering the concreted foundations of the existing grave markers at least one adjacent grave marker, that of an English sailor who was interred in the later 4

half of the 19 th Century was also substantially damaged with new cracks and broken pieces resulting from the nearby ground shaking. Broken shards of this damaged stone marker are presently stored off-site. Subsequently, six new markers were installed in the place of the historic markers. Power generators were heard and observed and the individuals who did the work made no attempt to notify either City or Mare Island Heritage Trust staff regarding the work that was carried out in this way. There is a combination-lock gate at the entry to the general area known as the Mare Island Shoreline Heritage Preserve where the cemetery is located and the individuals would have had to have had the combination to the gate or assistance from someone who did. Initially all the materials removed were strewn around a eucalyptus tree in the cemetery (Exhibit 1) and then at a later time the three intact gravestones and the brass identification plaques for the 3 broken off stones were removed entirely. Prior to the incident, and according to City of Vallejo City planning staff, a representative of the Mare Island Historic Park Foundation, which manages other City owned historic property on Mare Island, but not the cemetery, approached the City Planning Department and inquired about the process required for requesting the replacement of grave markers in this cemetery. He apparently made this inquiry on behalf of the Russian Consulate in San Francisco. He was apprised that there would need to be a Certificate of Appropriateness Permit application submitted which would involve a subsequent review of that application by the Architectural Heritage and Landmarks Commission. However, according to City planning staff, no final application was ever received for this request. Exhibit 2 The removed grave stones, a part of the National Historic Landmark (NHL) resource area, were dislodged from their resting places. Later, three grave stones were taken from the cemetery entirely and then apparently warehoused within the Mare Island Historic Park Foundation Museum facility. The three removed stones were apparently in relatively intact condition after their removal judging from Exhibit 1. These gravestones were replacement stones that likely took the place of wooden markers or unmarked graves 5

that most likely date from around 1896. The remaining three stones that had been vandalized or were otherwise broken off from age were further damaged in the removal process. These marble markers shown in Exhibit 2 and in their bases were collected and stored by the Mare Island Heritage Trust, the Preserve managing staff. Subsequently, six new markers were installed in the place of the historic markers that bear no similarity to other markers in this section of the cemetery in style, size, shape, color or material, and certainly not age, as these burial sites are in the oldest quadrant of the cemetery and thus all the grave markers in this section date from the mid to late Nineteenth Century. To be clear, this action involved the removal and damage of contributing resources to a National Historic Landmark that were located on public property under the ownership of the City of Vallejo. There are two significant factors regarding the actual legal disposition of the cemetery. As the cemetery was one of the transfer properties from the US Navy to the City, it is now held in title by the City of Vallejo. However, as it was also part of the February 2002, Settlement and Exchange Agreement between the City of Vallejo and the State of California, the cultural and historic resources on the property are also under the jurisdiction of the California State Lands Commission. The action therefore, involved the destruction and removal of unique and irreplaceable publically owned historic contributing resources to the National Landmark designation and as cultural artifacts under the jurisdiction of the State Lands Commission held in trust for all Californians through a grant from the State to the City. What is also problematic about this particular action at the cemetery is that it involves City owned land. The proponents of the action, essentially private citizens, lack the status of land owner or occupant with a supportable position or claim to petition the City and its Commission for review on the basis of the Certificate of Appropriateness procedure. Finally, the parties allegedly involved in this action have been entrusted by the City and community as guardians and custodians of other such historic resources and thus there is also the suggestion of a gross negligence or at minimum, recklessness in the handling of publically owned historic resources as demonstrated by these actions. b. The Aftereffects We now have six new grave markers placed in the NHL designated Mare Island Naval Cemetery. We are not attempting to argue issues related to aesthetics or preferences of taste. Again we refer to the procedure that the City has established for the review of proposals for any type of improvements or actions affecting identified historic resource areas within City jurisdiction that is based upon the Secretary of Interior standards for the treatment of historic properties. These published standards form the basis for preservation of resources such as the NHL designated cemetery. These standards describe four treatment categories: 1. Preservation 2. Rehabilitation 6

3. Restoration 4. Reconstruction While each project/property must be evaluated on an individual basis, these basic principles serve as a beginning approach. 3 The federal preservation program administering entity, the National Park Service, outlines these four treatment options for buildings on the National Register. These options are organized in a clear hierarchical framework. That is, the first is the preferred course of action, the second next, and so on. 4 The rationale for which of the four options should apply is based first on the historic status of the resource and secondly on the degree of need for the alteration of the resource resulting from some compelling requirement for new uses or contemporary needs. However in the instance of the cemetery and its status as a major contributing resource to a National Historic Landmark, it clearly falls within this first tier option for preservation as the subject resources are considered major contributing resources to the National Historic Landmark within a National Historic District. The preservation treatment is especially relevant for NHL resources and for other structures rated as individually eligible to the National Register. As the oldest Navy cemetery on the West Coast of America dating back to 1858, with numerous notable historical people and events memorialized there this point is irrefutable. Inversely, standards for Rehabilitation, the next level of treatment on the hierarchal list of treatments for such historic resources in our opinion should be not be applicable in this instance since other than protecting such resources from damage or deterioration, the property owner (the City) would otherwise have no cause or intention of "adding to or meeting continuing or new uses for such property or resources" 5 The preservation treatment is summarized as follows: Preservation, places a high premium on the retention of all historic fabric through conservation, maintenance and repair. It reflects a building s [historic resource s] continuum over time, through successive occupancies, and the respectful changes and alterations that are made. Preservation is defined as the act or process of applying measures necessary to sustain the existing form, integrity, and materials of an historic property. Work, including preliminary measures to protect and stabilize the property, generally focuses upon the ongoing maintenance and repair of historic materials and features rather than extensive replacement and new construction. New exterior additions are not within the scope of this treatment; however, the limited and sensitive upgrading of mechanical, electrical, and plumbing systems and other code-required work to make properties functional is appropriate within a preservation project. 6 Standards for Preservation Treatment: In the Mare Island Historic District, preservation is a treatment that should be used to maintain properties that are already in 3 Chapter 5 Mare Island Historic District Design Guidelines 4 Chapter 5 Mare Island Historic District Design Guidelines 5 City Staff Report for a Certificate of Appropriateness hearing before the AHLC Commission 6 Definition of Preservation from: The Secretary of the Interior s Standards for the Treatment of Historic Properties) 7

good condition and have a high degree of integrity. Best practices for maintenance should be used in a regular, cyclical manner to keep the property in proper condition. The preservation treatment is especially relevant for NHL resources and for other structures rated as individually eligible to the National Register, if they are already intact and in good condition, or after they have been restored 7. The following are excerpts from the Secretary of the Interiors Standards for Preservation that are particularly relevant: Keeping [consistency of uses] i.e. a building designed as a house will create less pressure for changes, for example, or adapting a house to office use may be a new use that also facilitates preservation. Preserve the historic character (continuum of a property s history). For example, the sidewalk design has changed along Officer s Row since its earliest history, but the existing material has taken on significance and helps to convey the evolution of the area. Stabilize, consolidate, and conserve existing historic materials. Specific procedures for these actions should be approved before undertaking any work. Replace minimum amount of fabric necessary and in kind (match materials). That is, since the property is being maintained, very little replacement should be needed. 8 Even if the next tier treatment, rehabilitation, was deemed as appropriate because of some compelling public benefit, based on the evaluative criteria used for another City-owned historic qualifying property that required a Certificate of Appropriateness application, the application for this particular action in our opinion would clearly fail to meet conditions of approval, as well: 1. A property will be used as it was historically or be given a new use that requires a minimum change to its distinctive materials, features, spaces and spatial relationships. 2. The historic character of the property (or resources within it) will be retained and preserved. The removal of historic materials or alteration of features or spaces that characterize the property will be avoided. 3. Each property will be recognized as a physical record of its time place and use. Changes that present a false sense of historic development such as adding conjectural features or elements from other historic properties would not be undertaken. 4. Changes to a property that has acquired historical significance in their own right will be retained and preserved. 7 Chapter 6 Preservation, Mare Island Historic District Design Guidelines 8 Ibid. 8

5. Distinctive materials, features, finishes and construction techniques or examples of craftsmanship that characterize a property will be preserved. 6. Deteriorated historic features will be repaired rather than replaced. When the severity of deterioration requires replacement of a distinctive feature, the new feature will match the old in design, color, texture and where possible materials. Replacement of missing pieces will be substantiated by documented and physical evidence. 7. Chemical or physical treatments if appropriate will be undertaken using the gentlest means possible. Treatments that cause damage to historic resources will not be used. 8. Archeological resources will be preserved and protected in place. If such resources must be disturbed, mitigation measures will be undertaken. 9. New additions, exterior alterations or related new construction would not destroy historic materials, features and spatial relationships that characterize the property. 10. New additions and adjacent or related new construction would be undertaken in such a manner that if removed in the future, the essential form and integrity of the property and surrounding environment would be unimpaired. 9 9 City Staff Report for a Certificate of Appropriateness hearing before the AHLC Commission July 8 th 2008 9

III. DISPOSITION OF THE RUSSIAN SAILOR GRAVE MARKERS PRIOR TO THEIR REMOVAL, DESTRUCTION AND REPLACEMENT The subject grave markers are those of six Russian sailors interred at the Mare Island Naval Cemetery in the19 th Century. Some of these six sailors served Rear-Admiral Popov s squadron that visited Mare Island from 1863 to1864 during the American Civil War. 10 What makes these burials of Russian sailors in a U.S. Naval cemetery of even greater significance is that the presence of this squadron reflected a spirit of cooperation between Russia and America. The Russian Navy was here during a time when the US naval defenses on the West Coast were overstretched due to the strains of the Civil War and the Russian presence helped strengthen the Exhibit 3 defensive position of Mare Island, the Navy s west coast headquarters, as possibly Confederate-leaning British and French war ships were present in the San Francisco Bay vicinity 11. An important foundation to establish here is an accurate assessment of what the condition of the Russian grave markers was like at the cemetery prior to the incident of their removal and replacement. What we know is that there are actually eight burial sites and markers for Russian sailors at the Mare Island Naval Cemetery spanning approximately 42 years in time and associated with at least two and perhaps three separate visits by Russian military ships. There was the previously mentioned 1863 era squadron commanded by the Rear-Admiral Popov and the 1904 visit of a Russian Naval Transport, the Lena that occurred during the Russo-Japanese war. There were two interments that occurred during the period the Lena was visiting Mare Island. The stones marking the 10 John Middleton THE RUSSIAN GRAVES AT THE NAVAL CEMETERY AT MARE ISLAND: 11 ibid 10

Lena burials were likely placed by the Russians themselves as they are larger, with a cruciform top, manufactured with granite instead of marble and are inscribed with Cyrillic writing to commemorate the lost Russian sailors. We have evidence that for three of the six sailors interred in the 1863 to 1900 era they either lacked any grave marker or were marked with wooden graves markers and consequently stone markers were placed for these grave sites some time in the late 19 th Century. 12 These replacement markers were austere standard issue US military style markers (Exhibit 3) while the other three were most probably remnant grave stones of the 1863 burials as shown in Exhibit 4. Consequently, at the time of the removal, there were a total of three styles of grave markers that memorialized the Russian sailors and the events that they Exhibit 4 are associated with: the existing and damaged original markers from the 1863 era, the US issued replacement stones that were installed in the late 1890s and then the two cruciform style stones installed in 1904 associated with the Lena. The disposition of the six removed grave markers from the 1863 to 1900 time period burials is at the center of the controversy that has resulted from their recent removal. As cited above, three of the removed markers were US issue grave markers used by the American military prior to and after the turn of the 20 th century. These stones are thought to be either replacements of older 1863 era gravestones or wooden markers, or they had been unmarked gravesites. The preponderance of grave stones in the quadrant where the six 1863 era burials occurred are primarily of mid to late nineteenth century style. This is not by coincidence. As dramatically pointed out by Carson La Belle, Captain, USN, Ret.: Military gravestones must be a particular shape, height, width, and depth. Soon after the establishment of fifteen national cemeteries including Arlington, by President Lincoln, the standards for military cemeteries were established. Fredrick Law Olmsted Sr. was 12 Correspondence between the medical director in charge at the Mare Island US Navy Hospital and the US Navy Surgeon General in Washington DC, 1895 & 1896 11

responsible for the initiation of the standards. He said a Federal Cemetery should be studiously simple to establish permanent dignity and tranquility and aesthetic standards. It was his intent to prevent one grave being decorated with huge, ostentatious gravestones when some families might afford them while others might not afford any. All soldiers, sailors and Marines gave equally in defense of their country; all should be honored and remembered in a similar manner. The official standards constrain the size or taste of a marker (gravestone) in a military cemetery. Regulations were imposed to set and preserve standards and were given congressional approval 13. Even the specific properties of the stones and the content of inscriptions were to be generally prescribed: In 1873 Congress legislated that headstones in military cemeteries nationwide were to be made of durable stone of such design and weight as shall keep them in place when set. It was decided that the new stones would be fashioned from granite or white marble, cut four inches thick, ten inches wide and a yard to a yard and a half long each tombstone slightly rounded on top, with an incised shield and a grave number, name of the deceased, his rank and home state. There have been very few modifications since the first of these appeared in 1874 in national cemeteries. In 1902 minor changes in the regulations for standard headstones were established. These changes were minimal, basically making headstones more durable, taller and thicker from front to back. The ranks of gravestones in this and all military cemeteries should be rigorously protected against the invasion of new and different style (i.e. unauthorized) monuments that utterly annihilate the sense of beauty and repose of the military personnel resting on that hillside All of the grave stones in this section of the cemetery have a concrete footing which may have been added at a later date to shore up stones that had begun to lean with time. The three Russian sailor markers that were of this standard issue type had Russian Sailor inscribed as their main labeling information. Adding some confusion to the prior existing condition of these markers was the fact that three of the sailors names had been lost so their inscriptions read Russian Sailor without their given names or rank. The three other markers are most likely remnants of the original 1863 markers however all three of these stones had been damaged with the marble headstones broken off and brass inscribed plaques installed as replacements for the missing stone markers. These brass plaques were placed adjoining the broken grave stones. Cursory measurements were taken by us of these older style markers and they are thinner than turn of the century era US issue style approximately an inch thick, but also wider approximately 16 inches wide. There were some other markers in this quadrant that resembled this type and all were in the 24 to 28 inch height range and it can be assumed that these stones were also of that height range. In contrast, the two Russian sailors from the Lena located in a quadrant with later burials had larger markers approximately 48 inches high with relatively massive granite block type foundations with the cruciform tops. 13 Correspondence from Carson La Belle, Captain, USN, Ret. 12

We have subsequently learned that two, and fragments of the third of these original 1863 era stones had been collected and stored off-site occurring over a period of time going as far back as 1995. The party that collected these fragments of the three stones recently delivered them to the facilities of the Mare Island Park Foundation, a principal proponent of the removal and replacement of the six historic grave markers. Why this original and authentic stone did not factor into the planning and implementation of the removal and replacement action is unexplained. Giving the benefit of the doubt to those who were either proponents of the removal of these stones or those who supported it being done, there was an apparent error in judgment made in the attempt at upgrading these historic 1863 era burial sites. Essentially the wrong template was used. By using the Lena 1904-1905 era stones, there resulted a historical misrepresentation. So, besides the loss of the actually historic materials there is also an error in representation and a period of forty-one years between the two burial events. The more recent Lena associated grave stones reflect an entirely different period of history. In an additional oversight uncovered by Mr. John Middleton an historian of Russian-American studies who has also been investigating this incident, the names of the prior unidentified sailors have been likely determined by the Russian State Naval Archives and yet this information was not incorporated into the new replacement stones and the sailor's ranks were incorrectly inscribed when compared to the original 1863 stones. Exhibit 5 shows four of the six newly installed gravestones in the Mare Island Naval Cemetery. Exhibit 5 13

IV. OPINION REGARDING THESE ACTIONS AND THEIR AFTERMATH The following analysis is a brief characterization of the referenced action and consequences as weighed against the criteria used in review regarding another Cityowned historic qualifying property that required a Certificate of Appropriateness application. In our opinion, the application for the cemetery grave stone demolition and replacement action would clearly fail to pass this review process. We provide the specific reasons why even under this more accommodating to new uses treatment standard, rehabilitation, this project and its consequences would be deemed inappropriate: 1. A property will be used as it was historically or be given a new use that requires a minimum change to its distinctive materials, features, spaces and spatial relationships. The action consisted of the complete removal of the historic artifacts and the introduction of new materials, out of context forms, a change in the color of the material and even substantial scale contrasts with the nearby and adjoining grave stones 2. The historic character of the property (or resources within it) will be retained and preserved. The removal of historic materials or alteration of features or spaces that characterize the property will be avoided. The action irreparably altered the character of the property and involved the complete removal of the historic artifacts and the introduction of new materials. 3. Each property will be recognized as a physical record of its time place and use. Changes that present a false sense of historic development such as adding conjectural features or elements from other historic properties would not be undertaken. The existing grave stones were the record and artifacts of the historical events that were memorialized there in the cemetery. The new stones present a false depiction of the historical record have been derived from a fabrication of new materials and based on a style type that was from a different century and therefore purely conjectural. One explanation given by a proponent of the project was that the new style looked and was stronger and therefore will be longer lasting than the original stones 14. 4. Changes to a property that has acquired historical significance in their own right will be retained and preserved. The three 1896 era replacement stones that were removed represent a significant historical event in their own right as the funding to place these stones came through a congressional appropriation which included funds specifically for this purpose. They were also the result of a re-interpretation of Navy policy in that prior to such funding the US Navy Surgeon General had determined that the issuance of headstones is restricted to unmarked graves of soldiers, sailors and 14 Interview with Father Silas Ruark, Antiochian Orthodox Church, one of the proponents of the installation of the new stones 14

marines and thus their funding and placement here represented either an exception or an extraordinary precedence setting event. 12 5. Distinctive materials, features, finishes and construction techniques or examples of craftsmanship that characterize a property will be preserved. The existing grave stones were the record and artifacts of the historical events that were memorialized there in the cemetery. The new stones present a contrived depiction of the historical record and are collectively a fabrication of a new style that is not derivative from or reflected in the grave markers in their vicinity. 6. Deteriorated historic features will be repaired rather than replaced. When the severity of deterioration requires replacement of a distinctive feature, the new feature will match the old in design, color, texture and where possible materials. Replacement of missing pieces will be substantiated by documented and physical evidence. The action involved entirely the opposite approach. Rather than repair, the existing markers were completely removed. But in addition to completely removing the existing markers, the materials and style of their replacements bore no resemblance what-so-ever to the prior existing stones. Finally to the best of our knowledge, there was no documentation to the procedures used or the rationale for why it was done in this fashion. 7. Chemical or physical treatments if appropriate will be undertaken using the gentlest means possible. Treatments that cause damage to historic resources will not be used. Workers were observed using electric jack-hammers powered by a generator and as shown in Exhibits 1 and 2, the existing historic stones were damaged in the process of their removal. 8. Archeological resources will be preserved and protected in place. If such resources must be disturbed, mitigation measures will be undertaken. Clearly preservation was not a consideration in manner in which these stones were removed and replaced let alone any consideration of protecting them in place. In fact that action was conducted in complete opposition to this measure. There was no mitigation undertaken in any fashion. 9. New additions, exterior alterations or related new construction would not destroy historic materials, features and spatial relationships that characterize the property. Not only were the subject six historic grave markers removed and damaged in the process of installing the six new markers but there is also evidence of collateral damage to a weakened adjoining marker as a result of the methods used in the removal of the existing stones. 15

10. New additions and adjacent or related new construction would be undertaken in such a manner that if removed in the future, the essential form and integrity of the property and surrounding environment would be unimpaired. Apparently no consideration was given to the integrity of the existing resource either in the intrinsic value of the historic materials or in the physical impact that their replacement would cause. Their removal would cause an additional impact on the general vicinity of their location especially absent a follow-up effort of the replacement of the original stones. 16

V. RECOMMENDATIONS As representatives of the Mare Island Heritage Trust, a nonprofit organization created specifically for the purpose of ensuring best uses of public lands on Mare Island and interim resource/park managers for the Mare Island Shoreline Heritage Preserve where the cemetery is situated, we feel a special sense of urgency and proprietary concern regarding this matter. Referring back to the standards and guidelines established by the Secretary of Interior regarding the disposition and treatment of historic properties and resources that we also have embraced as our own guidelines, we wish to emphasize that: Important historic properties cannot be replaced if they are destroyed. Preservation planning provides for conservative use of these properties. Preserving them in place and avoiding harm when possible and altering or destroying properties only when necessary Preservation goals should be oriented toward the greatest possible protection of properties in the historic context and should be based on the principle that properties should be preserved in place if possible, through affirmative treatments like rehabilitation, stabilization or restoration In other words in paraphrasing these guidelines we maintain that these historic grave markers in the cemetery are significant parts of its historic record and context the actual artifacts - and therefore their treatment must be handled with the highest degree of care and caution. We trust that the City would have considered these standards in its review process had a permit been submitted. What happened instead of this measured review process was a reckless act. We propose that the only acceptable course of action upon the determination by the Architectural Heritage and Landmarks Commission that this action was in fact not appropriate is the recommendation that the newly installed grave markers be removed. Additionally, we recommend that a panel of experts be consulted to determine the most suitable means for re-installing what remnants remain of the original artifacts. This analysis, repair and reinstallation should also include the collateral impacts such as the damaged adjoining grave stone of the English sailor. This also will necessitate the hiring of experienced gravestone restorers to repair and reset the original gravestones where they were removed in a manner deemed to be appropriate by cultural landscape professionals. The Trust will gladly assist the City in fund raising to ensure that these steps will be followed. This remedy also addresses the issue of precedence. As the cemetery has been altered from its historic state, it could open the door potentially for a variety of similar attempts by other interests wishing to add, replace or alter existing grave stones within the historic cemetery. This unequivocal corrective response to this action of attempting to replace and/or alter historic artifacts therefore also sends a clear message about how initiatives like this are addressed. 17

We also feel a strong sense of urgency to be preemptive regarding these events, in anticipation that these actions are establishing a new standard for the treatment of these important resources. Further, if we stand by silently, we may be perceived as being complicit. We feel there are several additional outcomes that need to be pursued: 1. First, a clear message must be sent that this is an isolated incident that cannot serve as precedent for any such action in the future. 2. Secondly, some type of restitution needs to be made for this failure to follow due process, conducting nonprofessional and poorly researched work resulting in the loss and degradation of important historic relics that contribute to the National Landmark cemetery. 3. Thirdly, the public and any outside party needs to be better informed about the protected status of this important National Landmark contributing resource. Perhaps an interpretive display should be designed and installed near the cemetery that describes the history and purpose of the cemetery, tells its stories and informs visitors about the cemetery s needs for restoration and how to do it in a way that preserves its historical value, rather than destroying it s historical integrity, as this action has done. 4. A complete inventory of all existing stones in the cemetery should be conducted and a conditions report prepared; 5. Install a web-viewable electronic surveillance system for the cemetery; 6. Repair and reset damaged gravestones surrounding the location where the stones were removed. 18

Bibliography & Citations 1. Chapter 5, Mare Island Historic District Design Guidelines 2. National Historic Landmarks website: http://tps.cr.nps.gov/nhl/ 3. Chapter 5 Mare Island Historic District Design Guidelines 4. Chapter 5 Mare Island Historic District Design Guidelines 5. City Staff Report for a Certificate of Appropriateness hearing before the AHLC Commission 6. Definition of Preservation from The Secretary of the Interior s Standards for the Treatment of Historic Properties 7. Chapter 6 Preservation, Mare Island Historic District Design Guidelines 8. Ibid. 9. City Staff Report for a Certificate of Appropriateness hearing before the AHLC Commission July 8 th 2008 10. John Middleton: THE RUSSIAN GRAVES AT THE NAVAL CEMETERY AT MARE ISLAND, Mr. Middleton is one of only five American historians of Russian-America's history to be awarded the Order of Friendship by the Russian government (Russia's highest decoration for foreign citizens), a foreign member of the Russian Academy of Science, Centre for Research on Russian America and Russian-American Relations, and hold an honorary Master of Science degree (History) from the Russian Naval Engineering Institute, with rank of Lieutenant in the Russian Navy. 11. Ibid 12. Correspondence between the medical director in charge at the Mare Island US Navy Hospital and the US Navy Surgeon General in Washington DC 13. Correspondence from Carson La Belle, Captain, USN, Ret. 14. Interview with Father Silas Ruark, Antiochian Orthodox Church, one of the proponents of the installation of the new stones 19