Fort Missoula Commons Historic Preservation Appeal

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PROJECT DESCRIPTION:

The Missoula City Council will hold a public hearing on an appeal to the May 3, 2023 Historic Preservation Commission (HPC) decisions to deny two permit applications regarding the proposed Fort Missoula Commons project, including (1) the historic preservation permit for the proposed exterior alterations to the historic post hospital building and new construction on the parcel located at 3255 Lt. Moss Road; and (2) The Historic Preservation Permit for the demolition of the garage on the same parcel.

The City’s zoning ordinance (20.85.100) provides that the Historic Preservation Commission’s denial of the two permits may be appealed within 30 days to City Council and sets forth the procedures for the appeal. An appeal was filed by the applicants on June 1, 2023. A City Council public hearing on the appeal is required by City zoning regulations. Under City law, the City Council must grant the HPC’s decision to deny the two permits a presumption of correctness, placing the burden of persuasion of error on the appellant.

PROJECT BACKGROUND:

On May 3, 2023, the Historic Preservation Commission voted to deny the historic preservation permit for the Fort Missoula Commons project.

City of Missoula Community Planning, Development, and Innovation received a complete application for two Historic Preservation Permits for the Post Hospital parcel located at 3255 Lt. Moss Rd. within the Fort Missoula Historic District and Historic Fort Missoula Neighborhood Character Overlay. The property is subject to review by the Missoula Historic Preservation Commission pursuant to Section 20.85.085 and 20.25.070 of the Missoula Title 20 Zoning Code.

Review criteria for Historic Preservation Permits for alterations and new construction can be found in Section 20.85.085 of the Missoula Title 20 Zoning Code. Additional review criteria for the Historic Fort Missoula Neighborhood Character Overlay can be found in Section 20.25.070 of the Missoula Title 20 Zoning Code. Review criteria for demolition of historic resources can be found in Section 20.85.085.J of the Missoula Title 20 Zoning Code.

PROJECT LINKS:

KEY DATES:

The Land Use and Planning Committee will be visiting the proposed development site that is the subject of the appeal made by Fort Missoula Commons. No formal presentations will be given; however appellant representatives and city staff are invited to be on site to answer committee member questions.

Due to the observance of a city holiday on Monday, February 19, 2024, the deadline for the appellants, Save the Fort, and City staff to submit a 5-page written response to the February 5, 2024 public hearing and a set of proposed findings of fact and conclusions of law for City Council's consideration has been changed to end of day on Monday, February 19th. The document will be posted on the Engage Missoula and included on the February 22, 2024 City Council agenda by 9:00 a.m. on February 20th.

On Monday, 01/08/2024, City Council voted to set the Fort Missoula Commons Historic Preservation Appeal Public Hearing for Monday, February 5, 2023.

The City Council Agenda with this item and related attachments will be posted at www.ci.missoula.mt.us/webcasts at least two days prior to the meeting.

FAE Missoula Hospital, LLC (Appellant), Save the Fort (amicus), and the City may submit briefs no longer than 20 pages, double-spaced, for the City Council's consideration by February 1, 2024 at 5:00 p.m. The pre-public hearing briefs will be posted for the public to view on Engage Missoula and www.ci.missoula.mt.us/webcasts no later than February 2, 2024 at 5:00 p.m.

Public hearing date: City Council Meeting. Monday, February 5, 2024 @ 6:00 pm.

Attorneys representing the appellants, Save the Fort and city staff may each submit a 5 page written response to the February 5, 2024 public hearing and a set of proposed findings of fact and conclusions of law for the City Council’s consideration. The documents will be posted on the Engage Missoula website and included on the City Council February 22, 2024 agenda.

The City Council will meet in special session to decide the appeal on February 22, 2024 at 9:00 a.m. Council will endeavor to finalize their decision at this meeting. The City Council meeting agenda will be posted two days prior by 5:00 p.m. at: www.ci.missoula.mt.us/webcasts.


PUBLIC COMMENTS:

Public Comments can be submitted to fortmissoulacommons@ci.missoula.mt.us or by mail to City Clerk, 435 Ryman, Missoula, MT 59802.

PROJECT PLANNER:

The project planner is Elizabeth Johnson, Historic Preservation Officer. She can be reached at johnsone@ci.missoula.mt.us

PROJECT DESCRIPTION:

The Missoula City Council will hold a public hearing on an appeal to the May 3, 2023 Historic Preservation Commission (HPC) decisions to deny two permit applications regarding the proposed Fort Missoula Commons project, including (1) the historic preservation permit for the proposed exterior alterations to the historic post hospital building and new construction on the parcel located at 3255 Lt. Moss Road; and (2) The Historic Preservation Permit for the demolition of the garage on the same parcel.

The City’s zoning ordinance (20.85.100) provides that the Historic Preservation Commission’s denial of the two permits may be appealed within 30 days to City Council and sets forth the procedures for the appeal. An appeal was filed by the applicants on June 1, 2023. A City Council public hearing on the appeal is required by City zoning regulations. Under City law, the City Council must grant the HPC’s decision to deny the two permits a presumption of correctness, placing the burden of persuasion of error on the appellant.

PROJECT BACKGROUND:

On May 3, 2023, the Historic Preservation Commission voted to deny the historic preservation permit for the Fort Missoula Commons project.

City of Missoula Community Planning, Development, and Innovation received a complete application for two Historic Preservation Permits for the Post Hospital parcel located at 3255 Lt. Moss Rd. within the Fort Missoula Historic District and Historic Fort Missoula Neighborhood Character Overlay. The property is subject to review by the Missoula Historic Preservation Commission pursuant to Section 20.85.085 and 20.25.070 of the Missoula Title 20 Zoning Code.

Review criteria for Historic Preservation Permits for alterations and new construction can be found in Section 20.85.085 of the Missoula Title 20 Zoning Code. Additional review criteria for the Historic Fort Missoula Neighborhood Character Overlay can be found in Section 20.25.070 of the Missoula Title 20 Zoning Code. Review criteria for demolition of historic resources can be found in Section 20.85.085.J of the Missoula Title 20 Zoning Code.

PROJECT LINKS:

KEY DATES:

The Land Use and Planning Committee will be visiting the proposed development site that is the subject of the appeal made by Fort Missoula Commons. No formal presentations will be given; however appellant representatives and city staff are invited to be on site to answer committee member questions.

Due to the observance of a city holiday on Monday, February 19, 2024, the deadline for the appellants, Save the Fort, and City staff to submit a 5-page written response to the February 5, 2024 public hearing and a set of proposed findings of fact and conclusions of law for City Council's consideration has been changed to end of day on Monday, February 19th. The document will be posted on the Engage Missoula and included on the February 22, 2024 City Council agenda by 9:00 a.m. on February 20th.

On Monday, 01/08/2024, City Council voted to set the Fort Missoula Commons Historic Preservation Appeal Public Hearing for Monday, February 5, 2023.

The City Council Agenda with this item and related attachments will be posted at www.ci.missoula.mt.us/webcasts at least two days prior to the meeting.

FAE Missoula Hospital, LLC (Appellant), Save the Fort (amicus), and the City may submit briefs no longer than 20 pages, double-spaced, for the City Council's consideration by February 1, 2024 at 5:00 p.m. The pre-public hearing briefs will be posted for the public to view on Engage Missoula and www.ci.missoula.mt.us/webcasts no later than February 2, 2024 at 5:00 p.m.

Public hearing date: City Council Meeting. Monday, February 5, 2024 @ 6:00 pm.

Attorneys representing the appellants, Save the Fort and city staff may each submit a 5 page written response to the February 5, 2024 public hearing and a set of proposed findings of fact and conclusions of law for the City Council’s consideration. The documents will be posted on the Engage Missoula website and included on the City Council February 22, 2024 agenda.

The City Council will meet in special session to decide the appeal on February 22, 2024 at 9:00 a.m. Council will endeavor to finalize their decision at this meeting. The City Council meeting agenda will be posted two days prior by 5:00 p.m. at: www.ci.missoula.mt.us/webcasts.


PUBLIC COMMENTS:

Public Comments can be submitted to fortmissoulacommons@ci.missoula.mt.us or by mail to City Clerk, 435 Ryman, Missoula, MT 59802.

PROJECT PLANNER:

The project planner is Elizabeth Johnson, Historic Preservation Officer. She can be reached at johnsone@ci.missoula.mt.us

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  • Share Please just allow the building of more housing on private land. It's beyond hypocritical of people across town living in their own houses to fight this progressive and smart effort. on Facebook Share Please just allow the building of more housing on private land. It's beyond hypocritical of people across town living in their own houses to fight this progressive and smart effort. on Twitter Share Please just allow the building of more housing on private land. It's beyond hypocritical of people across town living in their own houses to fight this progressive and smart effort. on Linkedin Email Please just allow the building of more housing on private land. It's beyond hypocritical of people across town living in their own houses to fight this progressive and smart effort. link

    Please just allow the building of more housing on private land. It's beyond hypocritical of people across town living in their own houses to fight this progressive and smart effort.

    Bedstuy asked 6 months ago

     

  • Share Back in 1994, some unscrupulous developers, backed by some equally shady—and illegal—practices by the UM Foundation, concluded that it would be a wonderful idea to build residential housing on Ft. Missoula. There was an immediate backlash and a dedicated group called Save the Fort was formed to prevent this travesty from proceeding. And STF was successful because they were in the right and genuinely cared about the fort. Now, here in 2024, another cabal of likewise calculating property developers, haughtily named Missoula Commons—Save the Old Post Hospital, have taken a different approach to building private dwellings on the former army post with the ploy of refurbishing the hospital in exchange for sixteen units of residential housing. The developers insist that their primary motive is selflessness, but, quite cynically, they will make the proverbial buttload of cash from these townhouses. I’m sorry, but it is not hard to see through their “altruism” for what it is…and it isn’t pretty. Fort Missoula is, in many ways, the City of Missoula’s most treasured community park, consisting of ball fields, museums, dog parks, and historical buildings utilized by nonprofits. It is also the site of one of the last remaining WWII internment camps that housed Japanese internees, Italian POWs, and a small number of Germans. It was never envisioned as having a private mini-town inside a public park—and it should not be. While the Missoula Commons cabal insists this housing is in keeping with the intent of the fort, there are a multitude of problems with the proposal starting with they knew full well that this proposal would be controversial and that there would be numerous hurdles to overcome including: • Rezoning for residential housing • Infrastructure that was lacking for 24/7 residential development such as adequate road access, city water upgrade and substantial sewage issues directly behind the proposed housing site, all of which will require tax-payer monies for considerable revitalization to meet code. This was pointed out during one of their open houses but was conveniently ignored by the Missoula Commons. • And finally, the cabal has owned the property for five years, yet made no attempt to repair the adjacent garage and allowed the lawn to die due to lack of watering—is this the behavior of truly compassionate and honest caretakers? I once was stationed at an Army Special Forces unit across the street from the post hospital and we utilized several of the surrounding structures, such as the post headquarters and the repelling tower. Back then, never would we have predicted that ruthless profiteers would attempt to degrade the historic post for personal gain. But, here they are...yet again. As a veteran, I find it disgusting that Missoula Commons would hold the hospital restoration hostage to greedy development on sacred land. As with the first attempt to build residential housing back in the 90s, this new attempt will fail, and fail for a multitude of reasons. Perhaps the best course of action for the Missoula Commons cabal is to announce that they are pulling out of the proposal and seek a less controversial area for development somewhere other than Ft. Missoula. And, if they are truly the altruistic LLC they claim to be—and genuinely care about the fort—they are certainly welcome to follow through with the restoration of the post hospital. on Facebook Share Back in 1994, some unscrupulous developers, backed by some equally shady—and illegal—practices by the UM Foundation, concluded that it would be a wonderful idea to build residential housing on Ft. Missoula. There was an immediate backlash and a dedicated group called Save the Fort was formed to prevent this travesty from proceeding. And STF was successful because they were in the right and genuinely cared about the fort. Now, here in 2024, another cabal of likewise calculating property developers, haughtily named Missoula Commons—Save the Old Post Hospital, have taken a different approach to building private dwellings on the former army post with the ploy of refurbishing the hospital in exchange for sixteen units of residential housing. The developers insist that their primary motive is selflessness, but, quite cynically, they will make the proverbial buttload of cash from these townhouses. I’m sorry, but it is not hard to see through their “altruism” for what it is…and it isn’t pretty. Fort Missoula is, in many ways, the City of Missoula’s most treasured community park, consisting of ball fields, museums, dog parks, and historical buildings utilized by nonprofits. It is also the site of one of the last remaining WWII internment camps that housed Japanese internees, Italian POWs, and a small number of Germans. It was never envisioned as having a private mini-town inside a public park—and it should not be. While the Missoula Commons cabal insists this housing is in keeping with the intent of the fort, there are a multitude of problems with the proposal starting with they knew full well that this proposal would be controversial and that there would be numerous hurdles to overcome including: • Rezoning for residential housing • Infrastructure that was lacking for 24/7 residential development such as adequate road access, city water upgrade and substantial sewage issues directly behind the proposed housing site, all of which will require tax-payer monies for considerable revitalization to meet code. This was pointed out during one of their open houses but was conveniently ignored by the Missoula Commons. • And finally, the cabal has owned the property for five years, yet made no attempt to repair the adjacent garage and allowed the lawn to die due to lack of watering—is this the behavior of truly compassionate and honest caretakers? I once was stationed at an Army Special Forces unit across the street from the post hospital and we utilized several of the surrounding structures, such as the post headquarters and the repelling tower. Back then, never would we have predicted that ruthless profiteers would attempt to degrade the historic post for personal gain. But, here they are...yet again. As a veteran, I find it disgusting that Missoula Commons would hold the hospital restoration hostage to greedy development on sacred land. As with the first attempt to build residential housing back in the 90s, this new attempt will fail, and fail for a multitude of reasons. Perhaps the best course of action for the Missoula Commons cabal is to announce that they are pulling out of the proposal and seek a less controversial area for development somewhere other than Ft. Missoula. And, if they are truly the altruistic LLC they claim to be—and genuinely care about the fort—they are certainly welcome to follow through with the restoration of the post hospital. on Twitter Share Back in 1994, some unscrupulous developers, backed by some equally shady—and illegal—practices by the UM Foundation, concluded that it would be a wonderful idea to build residential housing on Ft. Missoula. There was an immediate backlash and a dedicated group called Save the Fort was formed to prevent this travesty from proceeding. And STF was successful because they were in the right and genuinely cared about the fort. Now, here in 2024, another cabal of likewise calculating property developers, haughtily named Missoula Commons—Save the Old Post Hospital, have taken a different approach to building private dwellings on the former army post with the ploy of refurbishing the hospital in exchange for sixteen units of residential housing. The developers insist that their primary motive is selflessness, but, quite cynically, they will make the proverbial buttload of cash from these townhouses. I’m sorry, but it is not hard to see through their “altruism” for what it is…and it isn’t pretty. Fort Missoula is, in many ways, the City of Missoula’s most treasured community park, consisting of ball fields, museums, dog parks, and historical buildings utilized by nonprofits. It is also the site of one of the last remaining WWII internment camps that housed Japanese internees, Italian POWs, and a small number of Germans. It was never envisioned as having a private mini-town inside a public park—and it should not be. While the Missoula Commons cabal insists this housing is in keeping with the intent of the fort, there are a multitude of problems with the proposal starting with they knew full well that this proposal would be controversial and that there would be numerous hurdles to overcome including: • Rezoning for residential housing • Infrastructure that was lacking for 24/7 residential development such as adequate road access, city water upgrade and substantial sewage issues directly behind the proposed housing site, all of which will require tax-payer monies for considerable revitalization to meet code. This was pointed out during one of their open houses but was conveniently ignored by the Missoula Commons. • And finally, the cabal has owned the property for five years, yet made no attempt to repair the adjacent garage and allowed the lawn to die due to lack of watering—is this the behavior of truly compassionate and honest caretakers? I once was stationed at an Army Special Forces unit across the street from the post hospital and we utilized several of the surrounding structures, such as the post headquarters and the repelling tower. Back then, never would we have predicted that ruthless profiteers would attempt to degrade the historic post for personal gain. But, here they are...yet again. As a veteran, I find it disgusting that Missoula Commons would hold the hospital restoration hostage to greedy development on sacred land. As with the first attempt to build residential housing back in the 90s, this new attempt will fail, and fail for a multitude of reasons. Perhaps the best course of action for the Missoula Commons cabal is to announce that they are pulling out of the proposal and seek a less controversial area for development somewhere other than Ft. Missoula. And, if they are truly the altruistic LLC they claim to be—and genuinely care about the fort—they are certainly welcome to follow through with the restoration of the post hospital. on Linkedin Email Back in 1994, some unscrupulous developers, backed by some equally shady—and illegal—practices by the UM Foundation, concluded that it would be a wonderful idea to build residential housing on Ft. Missoula. There was an immediate backlash and a dedicated group called Save the Fort was formed to prevent this travesty from proceeding. And STF was successful because they were in the right and genuinely cared about the fort. Now, here in 2024, another cabal of likewise calculating property developers, haughtily named Missoula Commons—Save the Old Post Hospital, have taken a different approach to building private dwellings on the former army post with the ploy of refurbishing the hospital in exchange for sixteen units of residential housing. The developers insist that their primary motive is selflessness, but, quite cynically, they will make the proverbial buttload of cash from these townhouses. I’m sorry, but it is not hard to see through their “altruism” for what it is…and it isn’t pretty. Fort Missoula is, in many ways, the City of Missoula’s most treasured community park, consisting of ball fields, museums, dog parks, and historical buildings utilized by nonprofits. It is also the site of one of the last remaining WWII internment camps that housed Japanese internees, Italian POWs, and a small number of Germans. It was never envisioned as having a private mini-town inside a public park—and it should not be. While the Missoula Commons cabal insists this housing is in keeping with the intent of the fort, there are a multitude of problems with the proposal starting with they knew full well that this proposal would be controversial and that there would be numerous hurdles to overcome including: • Rezoning for residential housing • Infrastructure that was lacking for 24/7 residential development such as adequate road access, city water upgrade and substantial sewage issues directly behind the proposed housing site, all of which will require tax-payer monies for considerable revitalization to meet code. This was pointed out during one of their open houses but was conveniently ignored by the Missoula Commons. • And finally, the cabal has owned the property for five years, yet made no attempt to repair the adjacent garage and allowed the lawn to die due to lack of watering—is this the behavior of truly compassionate and honest caretakers? I once was stationed at an Army Special Forces unit across the street from the post hospital and we utilized several of the surrounding structures, such as the post headquarters and the repelling tower. Back then, never would we have predicted that ruthless profiteers would attempt to degrade the historic post for personal gain. But, here they are...yet again. As a veteran, I find it disgusting that Missoula Commons would hold the hospital restoration hostage to greedy development on sacred land. As with the first attempt to build residential housing back in the 90s, this new attempt will fail, and fail for a multitude of reasons. Perhaps the best course of action for the Missoula Commons cabal is to announce that they are pulling out of the proposal and seek a less controversial area for development somewhere other than Ft. Missoula. And, if they are truly the altruistic LLC they claim to be—and genuinely care about the fort—they are certainly welcome to follow through with the restoration of the post hospital. link

    Back in 1994, some unscrupulous developers, backed by some equally shady—and illegal—practices by the UM Foundation, concluded that it would be a wonderful idea to build residential housing on Ft. Missoula. There was an immediate backlash and a dedicated group called Save the Fort was formed to prevent this travesty from proceeding. And STF was successful because they were in the right and genuinely cared about the fort. Now, here in 2024, another cabal of likewise calculating property developers, haughtily named Missoula Commons—Save the Old Post Hospital, have taken a different approach to building private dwellings on the former army post with the ploy of refurbishing the hospital in exchange for sixteen units of residential housing. The developers insist that their primary motive is selflessness, but, quite cynically, they will make the proverbial buttload of cash from these townhouses. I’m sorry, but it is not hard to see through their “altruism” for what it is…and it isn’t pretty. Fort Missoula is, in many ways, the City of Missoula’s most treasured community park, consisting of ball fields, museums, dog parks, and historical buildings utilized by nonprofits. It is also the site of one of the last remaining WWII internment camps that housed Japanese internees, Italian POWs, and a small number of Germans. It was never envisioned as having a private mini-town inside a public park—and it should not be. While the Missoula Commons cabal insists this housing is in keeping with the intent of the fort, there are a multitude of problems with the proposal starting with they knew full well that this proposal would be controversial and that there would be numerous hurdles to overcome including: • Rezoning for residential housing • Infrastructure that was lacking for 24/7 residential development such as adequate road access, city water upgrade and substantial sewage issues directly behind the proposed housing site, all of which will require tax-payer monies for considerable revitalization to meet code. This was pointed out during one of their open houses but was conveniently ignored by the Missoula Commons. • And finally, the cabal has owned the property for five years, yet made no attempt to repair the adjacent garage and allowed the lawn to die due to lack of watering—is this the behavior of truly compassionate and honest caretakers? I once was stationed at an Army Special Forces unit across the street from the post hospital and we utilized several of the surrounding structures, such as the post headquarters and the repelling tower. Back then, never would we have predicted that ruthless profiteers would attempt to degrade the historic post for personal gain. But, here they are...yet again. As a veteran, I find it disgusting that Missoula Commons would hold the hospital restoration hostage to greedy development on sacred land. As with the first attempt to build residential housing back in the 90s, this new attempt will fail, and fail for a multitude of reasons. Perhaps the best course of action for the Missoula Commons cabal is to announce that they are pulling out of the proposal and seek a less controversial area for development somewhere other than Ft. Missoula. And, if they are truly the altruistic LLC they claim to be—and genuinely care about the fort—they are certainly welcome to follow through with the restoration of the post hospital.

    18ZSGM asked 5 months ago

     

  • Share Build it. This is great and should hopefully motivate more updates to the Fort. Those fighting it are supplying no other options, other than letting the hospital decay. This is a very odd thing for the community to becomes NIMBYs over. on Facebook Share Build it. This is great and should hopefully motivate more updates to the Fort. Those fighting it are supplying no other options, other than letting the hospital decay. This is a very odd thing for the community to becomes NIMBYs over. on Twitter Share Build it. This is great and should hopefully motivate more updates to the Fort. Those fighting it are supplying no other options, other than letting the hospital decay. This is a very odd thing for the community to becomes NIMBYs over. on Linkedin Email Build it. This is great and should hopefully motivate more updates to the Fort. Those fighting it are supplying no other options, other than letting the hospital decay. This is a very odd thing for the community to becomes NIMBYs over. link

    Build it. This is great and should hopefully motivate more updates to the Fort. Those fighting it are supplying no other options, other than letting the hospital decay. This is a very odd thing for the community to becomes NIMBYs over.

    Bedstuy asked 10 months ago

     

  • Share I do not support this project, Fort Missoula should not allow residential units. If the post hospital is in terrible shape, just tear it down and rewild the space. on Facebook Share I do not support this project, Fort Missoula should not allow residential units. If the post hospital is in terrible shape, just tear it down and rewild the space. on Twitter Share I do not support this project, Fort Missoula should not allow residential units. If the post hospital is in terrible shape, just tear it down and rewild the space. on Linkedin Email I do not support this project, Fort Missoula should not allow residential units. If the post hospital is in terrible shape, just tear it down and rewild the space. link

    I do not support this project, Fort Missoula should not allow residential units. If the post hospital is in terrible shape, just tear it down and rewild the space.

    Troy99 asked 9 months ago

     

  • Share When will comments posted to engage Missoula on the appeal be public ally viewable? on Facebook Share When will comments posted to engage Missoula on the appeal be public ally viewable? on Twitter Share When will comments posted to engage Missoula on the appeal be public ally viewable? on Linkedin Email When will comments posted to engage Missoula on the appeal be public ally viewable? link

    When will comments posted to engage Missoula on the appeal be public ally viewable?

    thula asked 10 months ago

     

  • Share Five Valleys Audubon Society September 15, 2023 To Missoula City Council: I am writing to expand on earlier comments about the proposed restoration of the Old Hospital Site that were sent to Mary McCrea from Gerhard Knudsen and Jim Brown representing Five Valleys Audubon Society in May, 2022. That letter is appended below. On July 14, 2022 we met with two developer's representatives from Strategies 360 and one from WGM to explain our concerns with the proposed development. We pointed out the important natural values and need for substantial building setback from the riparian zone of the Bitterroot River to protect the invaluable habitat. Then and since then, the developer has shown a complete lack of concern for this sensitive habitat. This lack of concern for impacts of development on natural values is a major reason for the alarming population loss experienced by many bird species in North America. I want to explain further why this proposed development would have a devastating and permanent impact on an important wildlife resource. The townhouses are proposed to be located immediately next to the inside channel of the Bitterroot River, which borders Sleven's Island. This is one of the most bird rich and wetland wildlife locations in the greater Missoula Valley. The inside channel supports particularly valuable riparian habitat. Both nesting and migrating birds commonly rely on this site as documented extensively by observations made by birders who submitted their observations to the eBird data base managed by Cornell University Lab of Ornithology. Sleven's Island is considered to be an eBird hotspot. Since 2015, 452 checklists from separate birding visits have been submitted to eBird. These birding observations have recorded a total of 178 species on Sleven's Island. This includes 30 species of songbirds that migrate here annually from Mexico, Central and South America. Ten of those species are warblers that represent all the warblers that can be expected to occur in western Montana. To protect valued riparian habitats from impacts of development non disturbance buffers must be provided where no building development occurs. These setback buffers are the distance from the edge of the riparian zone to where buildings may be constructed. The buffers are needed to allow birds and other wildlife to feel secure, find food and successfully raise young. We rely on results from 83 scientific studies to recommend size of setback buffers to protect riparian habitat (Ellis, Janet H., 2008.Scientific Recommendations on the Size of Stream Vegetated Buffers Needed to Protect Wildlife and Wildlife Habitat, Part Three, The Need for Stream Vegetated Buffers: What Does the Science Say? Report to Montana Department of Environmental Quality, 24 p). The recommended setback for a full complement of bird species along riparian corridors is 300-400 or more feet. For some species such as neotropic migrant songbirds a minimum of at least 150 feet might be adequate. The recently adopted Missoula County Riparian Resource Protection Zoning Regulations call for a 450 foot setback anywhere on the Bitterroot River. The proposed townhouses are to be placed 15 feet from the riparian zone. If this grossly insufficient setback is allowed to happen the townhouse development would result in a devastating and permanent impact to birds and other wildlife along this stretch of the Bitterroot River corridor. Residential living units should not be allowed on the Old Hospital site. The natural and historic values along Bitterroot River corridor in Fort Missoula is a treasure that needs protection for all citizens to enjoy now and in future generations. The developer needs to find other ways of financing restoration of the historic hospital. Letter to Mary McCrea, May 11, 2022 To Mary McCrae <mccream@ci.missoula.mt.us> From Gerhard Knudsen and Jim Brown During the past fifteen years, Five Valleys Audubon Society has offered comment on nearly all land development proposals under the jurisdiction of Missoula County. Our interest in doing so is to reduce the impact of such activity on areas having valued avian habitat. In pursuing this objective, we have sought to engage in the early phases of the review process. Our focus has been to offer comment on the habitat values of a site and suggest means to mitigate impacts of a prospective development. In the end, we are hopeful that developers will then seek to integrate our suggestions into their ultimate plan of development. Development projects within the jurisdiction of the city rarely have the potential to affect valued avian environments. That being the case, we have not offered comment on such undertakings. The proposed Fort Missoula Commons, however, is a development within the purview of the city that will doubtlessly have an impact on bird habitat. Our interest in this project centers on its implications to adjoining riparian cottonwood and associated wetland habitat. Riparian areas are habitats occupying less than four percent of Montana’s land area. Significantly, they are used by more than 80 percent of the bird species found in the state during all or part of the year. No other habitat in the West supports a higher diversity of breeding birds. Riparian habitat adjoining the proposed Fort Missoula Commons development lies within the Clark Fork River-Grass Valley Important Bird Area. An international conservation effort, the Important Bird Area (IBA) program is aimed at identifying locations with healthy bird populations and encouraging conservation measures that protect the underlying habitat. Extensive data collected by the Five Valleys Audubon Society documented 246 bird species within the IBA. That is more than half the number of species recorded for the entire state. Thirteen of the species were breeding populations of birds having a high conservation priority. Due to the large number of Lewis’s Woodpeckers, a species of special conservation concern, the status of the IBA was raised to one of “continental significance.” Importantly, the land development being proposed for Fort Missoula lies within a migration corridor in the Missoula Valley, a fact well-established by repeated bird surveys within the IBA. Recent scientific studies conducted by Project Night Flight Inc. further attest to this fact. As part of that research, more than 50 bioacoustic recorders have been located throughout the Bitterroot Valley and into the south end of the Missoula Valley. The research focus is birds that migrate during the night and then land in “stopover” habitat each day to rest and feed. When migrating at night, birds frequently give calls, possibly to echolocate, communicate with other birds or maintain flock spacing and cohesion. Acoustic monitoring technology records those calls during the entire migration period and subsequent analysis determines the species involved and their numbers. Results of the Night Flight research reveal that, during the fall, thousands of birds comprising many species migrate at night though these valleys and stop over during the day. Bird numbers are greatest where valleys narrow at pinch points such as the juncture of the Missoula and Bitterroot Valleys. Bird use documented on the adjoining Knife River Pond area further affirms that the general area is on a migratory bird pathway. During the past several years, 227 bird species have been observed by birders submitting records to the Cornell University Lab of Ornithology’s “eBird” database. The pond area is considered a birding “hotspot” and its species count is among the highest in the state. The Knife River Ponds and neighboring University of Montana land comprise a rich natural resource and offer an opportunity to become a treasured natural area easily accessible to Missoula's citizens. Along with the ponds, a natural area would include adjoining University property that supports the University's Bird Ecology Lab, native plant garden, undeveloped grassland and riparian habitat. The natural area concept that is now being explored envisions the area being managed to protect its significant natural values for the education and enjoyment of Missoula's citizens. It is worthy of note that the area would include valued riparian habitat abutting land where the Fort Missoula Commons project would be sited. It is the riparian environment found on Slevin’s Island, one of Missoula’s most popular birding areas and where a rich diversity of bird species has been documented. As the Missoula community deliberates on the proposed Fort Missoula Commons development, it seems imperative that the dialogue address its implications to the area’s natural values as well as current and future uses of adjoining property. Our interest at this point is to promote that dialogue and offer some background about the habitat values of the area and provide a broader context to the development. We would be particularly interested in discussions regarding mitigative action needed to limit the impact of the planned development on adjoining avian habitat. If you feel it would be helpful, we would welcome the opportunity to meet with you and discuss our concerns in further detail. Jim Brown Five Valleys Audubon Conservation Chair on Facebook Share Five Valleys Audubon Society September 15, 2023 To Missoula City Council: I am writing to expand on earlier comments about the proposed restoration of the Old Hospital Site that were sent to Mary McCrea from Gerhard Knudsen and Jim Brown representing Five Valleys Audubon Society in May, 2022. That letter is appended below. On July 14, 2022 we met with two developer's representatives from Strategies 360 and one from WGM to explain our concerns with the proposed development. We pointed out the important natural values and need for substantial building setback from the riparian zone of the Bitterroot River to protect the invaluable habitat. Then and since then, the developer has shown a complete lack of concern for this sensitive habitat. This lack of concern for impacts of development on natural values is a major reason for the alarming population loss experienced by many bird species in North America. I want to explain further why this proposed development would have a devastating and permanent impact on an important wildlife resource. The townhouses are proposed to be located immediately next to the inside channel of the Bitterroot River, which borders Sleven's Island. This is one of the most bird rich and wetland wildlife locations in the greater Missoula Valley. The inside channel supports particularly valuable riparian habitat. Both nesting and migrating birds commonly rely on this site as documented extensively by observations made by birders who submitted their observations to the eBird data base managed by Cornell University Lab of Ornithology. Sleven's Island is considered to be an eBird hotspot. Since 2015, 452 checklists from separate birding visits have been submitted to eBird. These birding observations have recorded a total of 178 species on Sleven's Island. This includes 30 species of songbirds that migrate here annually from Mexico, Central and South America. Ten of those species are warblers that represent all the warblers that can be expected to occur in western Montana. To protect valued riparian habitats from impacts of development non disturbance buffers must be provided where no building development occurs. These setback buffers are the distance from the edge of the riparian zone to where buildings may be constructed. The buffers are needed to allow birds and other wildlife to feel secure, find food and successfully raise young. We rely on results from 83 scientific studies to recommend size of setback buffers to protect riparian habitat (Ellis, Janet H., 2008.Scientific Recommendations on the Size of Stream Vegetated Buffers Needed to Protect Wildlife and Wildlife Habitat, Part Three, The Need for Stream Vegetated Buffers: What Does the Science Say? Report to Montana Department of Environmental Quality, 24 p). The recommended setback for a full complement of bird species along riparian corridors is 300-400 or more feet. For some species such as neotropic migrant songbirds a minimum of at least 150 feet might be adequate. The recently adopted Missoula County Riparian Resource Protection Zoning Regulations call for a 450 foot setback anywhere on the Bitterroot River. The proposed townhouses are to be placed 15 feet from the riparian zone. If this grossly insufficient setback is allowed to happen the townhouse development would result in a devastating and permanent impact to birds and other wildlife along this stretch of the Bitterroot River corridor. Residential living units should not be allowed on the Old Hospital site. The natural and historic values along Bitterroot River corridor in Fort Missoula is a treasure that needs protection for all citizens to enjoy now and in future generations. The developer needs to find other ways of financing restoration of the historic hospital. Letter to Mary McCrea, May 11, 2022 To Mary McCrae <mccream@ci.missoula.mt.us> From Gerhard Knudsen and Jim Brown During the past fifteen years, Five Valleys Audubon Society has offered comment on nearly all land development proposals under the jurisdiction of Missoula County. Our interest in doing so is to reduce the impact of such activity on areas having valued avian habitat. In pursuing this objective, we have sought to engage in the early phases of the review process. Our focus has been to offer comment on the habitat values of a site and suggest means to mitigate impacts of a prospective development. In the end, we are hopeful that developers will then seek to integrate our suggestions into their ultimate plan of development. Development projects within the jurisdiction of the city rarely have the potential to affect valued avian environments. That being the case, we have not offered comment on such undertakings. The proposed Fort Missoula Commons, however, is a development within the purview of the city that will doubtlessly have an impact on bird habitat. Our interest in this project centers on its implications to adjoining riparian cottonwood and associated wetland habitat. Riparian areas are habitats occupying less than four percent of Montana’s land area. Significantly, they are used by more than 80 percent of the bird species found in the state during all or part of the year. No other habitat in the West supports a higher diversity of breeding birds. Riparian habitat adjoining the proposed Fort Missoula Commons development lies within the Clark Fork River-Grass Valley Important Bird Area. An international conservation effort, the Important Bird Area (IBA) program is aimed at identifying locations with healthy bird populations and encouraging conservation measures that protect the underlying habitat. Extensive data collected by the Five Valleys Audubon Society documented 246 bird species within the IBA. That is more than half the number of species recorded for the entire state. Thirteen of the species were breeding populations of birds having a high conservation priority. Due to the large number of Lewis’s Woodpeckers, a species of special conservation concern, the status of the IBA was raised to one of “continental significance.” Importantly, the land development being proposed for Fort Missoula lies within a migration corridor in the Missoula Valley, a fact well-established by repeated bird surveys within the IBA. Recent scientific studies conducted by Project Night Flight Inc. further attest to this fact. As part of that research, more than 50 bioacoustic recorders have been located throughout the Bitterroot Valley and into the south end of the Missoula Valley. The research focus is birds that migrate during the night and then land in “stopover” habitat each day to rest and feed. When migrating at night, birds frequently give calls, possibly to echolocate, communicate with other birds or maintain flock spacing and cohesion. Acoustic monitoring technology records those calls during the entire migration period and subsequent analysis determines the species involved and their numbers. Results of the Night Flight research reveal that, during the fall, thousands of birds comprising many species migrate at night though these valleys and stop over during the day. Bird numbers are greatest where valleys narrow at pinch points such as the juncture of the Missoula and Bitterroot Valleys. Bird use documented on the adjoining Knife River Pond area further affirms that the general area is on a migratory bird pathway. During the past several years, 227 bird species have been observed by birders submitting records to the Cornell University Lab of Ornithology’s “eBird” database. The pond area is considered a birding “hotspot” and its species count is among the highest in the state. The Knife River Ponds and neighboring University of Montana land comprise a rich natural resource and offer an opportunity to become a treasured natural area easily accessible to Missoula's citizens. Along with the ponds, a natural area would include adjoining University property that supports the University's Bird Ecology Lab, native plant garden, undeveloped grassland and riparian habitat. The natural area concept that is now being explored envisions the area being managed to protect its significant natural values for the education and enjoyment of Missoula's citizens. It is worthy of note that the area would include valued riparian habitat abutting land where the Fort Missoula Commons project would be sited. It is the riparian environment found on Slevin’s Island, one of Missoula’s most popular birding areas and where a rich diversity of bird species has been documented. As the Missoula community deliberates on the proposed Fort Missoula Commons development, it seems imperative that the dialogue address its implications to the area’s natural values as well as current and future uses of adjoining property. Our interest at this point is to promote that dialogue and offer some background about the habitat values of the area and provide a broader context to the development. We would be particularly interested in discussions regarding mitigative action needed to limit the impact of the planned development on adjoining avian habitat. If you feel it would be helpful, we would welcome the opportunity to meet with you and discuss our concerns in further detail. Jim Brown Five Valleys Audubon Conservation Chair on Twitter Share Five Valleys Audubon Society September 15, 2023 To Missoula City Council: I am writing to expand on earlier comments about the proposed restoration of the Old Hospital Site that were sent to Mary McCrea from Gerhard Knudsen and Jim Brown representing Five Valleys Audubon Society in May, 2022. That letter is appended below. On July 14, 2022 we met with two developer's representatives from Strategies 360 and one from WGM to explain our concerns with the proposed development. We pointed out the important natural values and need for substantial building setback from the riparian zone of the Bitterroot River to protect the invaluable habitat. Then and since then, the developer has shown a complete lack of concern for this sensitive habitat. This lack of concern for impacts of development on natural values is a major reason for the alarming population loss experienced by many bird species in North America. I want to explain further why this proposed development would have a devastating and permanent impact on an important wildlife resource. The townhouses are proposed to be located immediately next to the inside channel of the Bitterroot River, which borders Sleven's Island. This is one of the most bird rich and wetland wildlife locations in the greater Missoula Valley. The inside channel supports particularly valuable riparian habitat. Both nesting and migrating birds commonly rely on this site as documented extensively by observations made by birders who submitted their observations to the eBird data base managed by Cornell University Lab of Ornithology. Sleven's Island is considered to be an eBird hotspot. Since 2015, 452 checklists from separate birding visits have been submitted to eBird. These birding observations have recorded a total of 178 species on Sleven's Island. This includes 30 species of songbirds that migrate here annually from Mexico, Central and South America. Ten of those species are warblers that represent all the warblers that can be expected to occur in western Montana. To protect valued riparian habitats from impacts of development non disturbance buffers must be provided where no building development occurs. These setback buffers are the distance from the edge of the riparian zone to where buildings may be constructed. The buffers are needed to allow birds and other wildlife to feel secure, find food and successfully raise young. We rely on results from 83 scientific studies to recommend size of setback buffers to protect riparian habitat (Ellis, Janet H., 2008.Scientific Recommendations on the Size of Stream Vegetated Buffers Needed to Protect Wildlife and Wildlife Habitat, Part Three, The Need for Stream Vegetated Buffers: What Does the Science Say? Report to Montana Department of Environmental Quality, 24 p). The recommended setback for a full complement of bird species along riparian corridors is 300-400 or more feet. For some species such as neotropic migrant songbirds a minimum of at least 150 feet might be adequate. The recently adopted Missoula County Riparian Resource Protection Zoning Regulations call for a 450 foot setback anywhere on the Bitterroot River. The proposed townhouses are to be placed 15 feet from the riparian zone. If this grossly insufficient setback is allowed to happen the townhouse development would result in a devastating and permanent impact to birds and other wildlife along this stretch of the Bitterroot River corridor. Residential living units should not be allowed on the Old Hospital site. The natural and historic values along Bitterroot River corridor in Fort Missoula is a treasure that needs protection for all citizens to enjoy now and in future generations. The developer needs to find other ways of financing restoration of the historic hospital. Letter to Mary McCrea, May 11, 2022 To Mary McCrae <mccream@ci.missoula.mt.us> From Gerhard Knudsen and Jim Brown During the past fifteen years, Five Valleys Audubon Society has offered comment on nearly all land development proposals under the jurisdiction of Missoula County. Our interest in doing so is to reduce the impact of such activity on areas having valued avian habitat. In pursuing this objective, we have sought to engage in the early phases of the review process. Our focus has been to offer comment on the habitat values of a site and suggest means to mitigate impacts of a prospective development. In the end, we are hopeful that developers will then seek to integrate our suggestions into their ultimate plan of development. Development projects within the jurisdiction of the city rarely have the potential to affect valued avian environments. That being the case, we have not offered comment on such undertakings. The proposed Fort Missoula Commons, however, is a development within the purview of the city that will doubtlessly have an impact on bird habitat. Our interest in this project centers on its implications to adjoining riparian cottonwood and associated wetland habitat. Riparian areas are habitats occupying less than four percent of Montana’s land area. Significantly, they are used by more than 80 percent of the bird species found in the state during all or part of the year. No other habitat in the West supports a higher diversity of breeding birds. Riparian habitat adjoining the proposed Fort Missoula Commons development lies within the Clark Fork River-Grass Valley Important Bird Area. An international conservation effort, the Important Bird Area (IBA) program is aimed at identifying locations with healthy bird populations and encouraging conservation measures that protect the underlying habitat. Extensive data collected by the Five Valleys Audubon Society documented 246 bird species within the IBA. That is more than half the number of species recorded for the entire state. Thirteen of the species were breeding populations of birds having a high conservation priority. Due to the large number of Lewis’s Woodpeckers, a species of special conservation concern, the status of the IBA was raised to one of “continental significance.” Importantly, the land development being proposed for Fort Missoula lies within a migration corridor in the Missoula Valley, a fact well-established by repeated bird surveys within the IBA. Recent scientific studies conducted by Project Night Flight Inc. further attest to this fact. As part of that research, more than 50 bioacoustic recorders have been located throughout the Bitterroot Valley and into the south end of the Missoula Valley. The research focus is birds that migrate during the night and then land in “stopover” habitat each day to rest and feed. When migrating at night, birds frequently give calls, possibly to echolocate, communicate with other birds or maintain flock spacing and cohesion. Acoustic monitoring technology records those calls during the entire migration period and subsequent analysis determines the species involved and their numbers. Results of the Night Flight research reveal that, during the fall, thousands of birds comprising many species migrate at night though these valleys and stop over during the day. Bird numbers are greatest where valleys narrow at pinch points such as the juncture of the Missoula and Bitterroot Valleys. Bird use documented on the adjoining Knife River Pond area further affirms that the general area is on a migratory bird pathway. During the past several years, 227 bird species have been observed by birders submitting records to the Cornell University Lab of Ornithology’s “eBird” database. The pond area is considered a birding “hotspot” and its species count is among the highest in the state. The Knife River Ponds and neighboring University of Montana land comprise a rich natural resource and offer an opportunity to become a treasured natural area easily accessible to Missoula's citizens. Along with the ponds, a natural area would include adjoining University property that supports the University's Bird Ecology Lab, native plant garden, undeveloped grassland and riparian habitat. The natural area concept that is now being explored envisions the area being managed to protect its significant natural values for the education and enjoyment of Missoula's citizens. It is worthy of note that the area would include valued riparian habitat abutting land where the Fort Missoula Commons project would be sited. It is the riparian environment found on Slevin’s Island, one of Missoula’s most popular birding areas and where a rich diversity of bird species has been documented. As the Missoula community deliberates on the proposed Fort Missoula Commons development, it seems imperative that the dialogue address its implications to the area’s natural values as well as current and future uses of adjoining property. Our interest at this point is to promote that dialogue and offer some background about the habitat values of the area and provide a broader context to the development. We would be particularly interested in discussions regarding mitigative action needed to limit the impact of the planned development on adjoining avian habitat. If you feel it would be helpful, we would welcome the opportunity to meet with you and discuss our concerns in further detail. Jim Brown Five Valleys Audubon Conservation Chair on Linkedin Email Five Valleys Audubon Society September 15, 2023 To Missoula City Council: I am writing to expand on earlier comments about the proposed restoration of the Old Hospital Site that were sent to Mary McCrea from Gerhard Knudsen and Jim Brown representing Five Valleys Audubon Society in May, 2022. That letter is appended below. On July 14, 2022 we met with two developer's representatives from Strategies 360 and one from WGM to explain our concerns with the proposed development. We pointed out the important natural values and need for substantial building setback from the riparian zone of the Bitterroot River to protect the invaluable habitat. Then and since then, the developer has shown a complete lack of concern for this sensitive habitat. This lack of concern for impacts of development on natural values is a major reason for the alarming population loss experienced by many bird species in North America. I want to explain further why this proposed development would have a devastating and permanent impact on an important wildlife resource. The townhouses are proposed to be located immediately next to the inside channel of the Bitterroot River, which borders Sleven's Island. This is one of the most bird rich and wetland wildlife locations in the greater Missoula Valley. The inside channel supports particularly valuable riparian habitat. Both nesting and migrating birds commonly rely on this site as documented extensively by observations made by birders who submitted their observations to the eBird data base managed by Cornell University Lab of Ornithology. Sleven's Island is considered to be an eBird hotspot. Since 2015, 452 checklists from separate birding visits have been submitted to eBird. These birding observations have recorded a total of 178 species on Sleven's Island. This includes 30 species of songbirds that migrate here annually from Mexico, Central and South America. Ten of those species are warblers that represent all the warblers that can be expected to occur in western Montana. To protect valued riparian habitats from impacts of development non disturbance buffers must be provided where no building development occurs. These setback buffers are the distance from the edge of the riparian zone to where buildings may be constructed. The buffers are needed to allow birds and other wildlife to feel secure, find food and successfully raise young. We rely on results from 83 scientific studies to recommend size of setback buffers to protect riparian habitat (Ellis, Janet H., 2008.Scientific Recommendations on the Size of Stream Vegetated Buffers Needed to Protect Wildlife and Wildlife Habitat, Part Three, The Need for Stream Vegetated Buffers: What Does the Science Say? Report to Montana Department of Environmental Quality, 24 p). The recommended setback for a full complement of bird species along riparian corridors is 300-400 or more feet. For some species such as neotropic migrant songbirds a minimum of at least 150 feet might be adequate. The recently adopted Missoula County Riparian Resource Protection Zoning Regulations call for a 450 foot setback anywhere on the Bitterroot River. The proposed townhouses are to be placed 15 feet from the riparian zone. If this grossly insufficient setback is allowed to happen the townhouse development would result in a devastating and permanent impact to birds and other wildlife along this stretch of the Bitterroot River corridor. Residential living units should not be allowed on the Old Hospital site. The natural and historic values along Bitterroot River corridor in Fort Missoula is a treasure that needs protection for all citizens to enjoy now and in future generations. The developer needs to find other ways of financing restoration of the historic hospital. Letter to Mary McCrea, May 11, 2022 To Mary McCrae <mccream@ci.missoula.mt.us> From Gerhard Knudsen and Jim Brown During the past fifteen years, Five Valleys Audubon Society has offered comment on nearly all land development proposals under the jurisdiction of Missoula County. Our interest in doing so is to reduce the impact of such activity on areas having valued avian habitat. In pursuing this objective, we have sought to engage in the early phases of the review process. Our focus has been to offer comment on the habitat values of a site and suggest means to mitigate impacts of a prospective development. In the end, we are hopeful that developers will then seek to integrate our suggestions into their ultimate plan of development. Development projects within the jurisdiction of the city rarely have the potential to affect valued avian environments. That being the case, we have not offered comment on such undertakings. The proposed Fort Missoula Commons, however, is a development within the purview of the city that will doubtlessly have an impact on bird habitat. Our interest in this project centers on its implications to adjoining riparian cottonwood and associated wetland habitat. Riparian areas are habitats occupying less than four percent of Montana’s land area. Significantly, they are used by more than 80 percent of the bird species found in the state during all or part of the year. No other habitat in the West supports a higher diversity of breeding birds. Riparian habitat adjoining the proposed Fort Missoula Commons development lies within the Clark Fork River-Grass Valley Important Bird Area. An international conservation effort, the Important Bird Area (IBA) program is aimed at identifying locations with healthy bird populations and encouraging conservation measures that protect the underlying habitat. Extensive data collected by the Five Valleys Audubon Society documented 246 bird species within the IBA. That is more than half the number of species recorded for the entire state. Thirteen of the species were breeding populations of birds having a high conservation priority. Due to the large number of Lewis’s Woodpeckers, a species of special conservation concern, the status of the IBA was raised to one of “continental significance.” Importantly, the land development being proposed for Fort Missoula lies within a migration corridor in the Missoula Valley, a fact well-established by repeated bird surveys within the IBA. Recent scientific studies conducted by Project Night Flight Inc. further attest to this fact. As part of that research, more than 50 bioacoustic recorders have been located throughout the Bitterroot Valley and into the south end of the Missoula Valley. The research focus is birds that migrate during the night and then land in “stopover” habitat each day to rest and feed. When migrating at night, birds frequently give calls, possibly to echolocate, communicate with other birds or maintain flock spacing and cohesion. Acoustic monitoring technology records those calls during the entire migration period and subsequent analysis determines the species involved and their numbers. Results of the Night Flight research reveal that, during the fall, thousands of birds comprising many species migrate at night though these valleys and stop over during the day. Bird numbers are greatest where valleys narrow at pinch points such as the juncture of the Missoula and Bitterroot Valleys. Bird use documented on the adjoining Knife River Pond area further affirms that the general area is on a migratory bird pathway. During the past several years, 227 bird species have been observed by birders submitting records to the Cornell University Lab of Ornithology’s “eBird” database. The pond area is considered a birding “hotspot” and its species count is among the highest in the state. The Knife River Ponds and neighboring University of Montana land comprise a rich natural resource and offer an opportunity to become a treasured natural area easily accessible to Missoula's citizens. Along with the ponds, a natural area would include adjoining University property that supports the University's Bird Ecology Lab, native plant garden, undeveloped grassland and riparian habitat. The natural area concept that is now being explored envisions the area being managed to protect its significant natural values for the education and enjoyment of Missoula's citizens. It is worthy of note that the area would include valued riparian habitat abutting land where the Fort Missoula Commons project would be sited. It is the riparian environment found on Slevin’s Island, one of Missoula’s most popular birding areas and where a rich diversity of bird species has been documented. As the Missoula community deliberates on the proposed Fort Missoula Commons development, it seems imperative that the dialogue address its implications to the area’s natural values as well as current and future uses of adjoining property. Our interest at this point is to promote that dialogue and offer some background about the habitat values of the area and provide a broader context to the development. We would be particularly interested in discussions regarding mitigative action needed to limit the impact of the planned development on adjoining avian habitat. If you feel it would be helpful, we would welcome the opportunity to meet with you and discuss our concerns in further detail. Jim Brown Five Valleys Audubon Conservation Chair link

    Five Valleys Audubon Society September 15, 2023 To Missoula City Council: I am writing to expand on earlier comments about the proposed restoration of the Old Hospital Site that were sent to Mary McCrea from Gerhard Knudsen and Jim Brown representing Five Valleys Audubon Society in May, 2022. That letter is appended below. On July 14, 2022 we met with two developer's representatives from Strategies 360 and one from WGM to explain our concerns with the proposed development. We pointed out the important natural values and need for substantial building setback from the riparian zone of the Bitterroot River to protect the invaluable habitat. Then and since then, the developer has shown a complete lack of concern for this sensitive habitat. This lack of concern for impacts of development on natural values is a major reason for the alarming population loss experienced by many bird species in North America. I want to explain further why this proposed development would have a devastating and permanent impact on an important wildlife resource. The townhouses are proposed to be located immediately next to the inside channel of the Bitterroot River, which borders Sleven's Island. This is one of the most bird rich and wetland wildlife locations in the greater Missoula Valley. The inside channel supports particularly valuable riparian habitat. Both nesting and migrating birds commonly rely on this site as documented extensively by observations made by birders who submitted their observations to the eBird data base managed by Cornell University Lab of Ornithology. Sleven's Island is considered to be an eBird hotspot. Since 2015, 452 checklists from separate birding visits have been submitted to eBird. These birding observations have recorded a total of 178 species on Sleven's Island. This includes 30 species of songbirds that migrate here annually from Mexico, Central and South America. Ten of those species are warblers that represent all the warblers that can be expected to occur in western Montana. To protect valued riparian habitats from impacts of development non disturbance buffers must be provided where no building development occurs. These setback buffers are the distance from the edge of the riparian zone to where buildings may be constructed. The buffers are needed to allow birds and other wildlife to feel secure, find food and successfully raise young. We rely on results from 83 scientific studies to recommend size of setback buffers to protect riparian habitat (Ellis, Janet H., 2008.Scientific Recommendations on the Size of Stream Vegetated Buffers Needed to Protect Wildlife and Wildlife Habitat, Part Three, The Need for Stream Vegetated Buffers: What Does the Science Say? Report to Montana Department of Environmental Quality, 24 p). The recommended setback for a full complement of bird species along riparian corridors is 300-400 or more feet. For some species such as neotropic migrant songbirds a minimum of at least 150 feet might be adequate. The recently adopted Missoula County Riparian Resource Protection Zoning Regulations call for a 450 foot setback anywhere on the Bitterroot River. The proposed townhouses are to be placed 15 feet from the riparian zone. If this grossly insufficient setback is allowed to happen the townhouse development would result in a devastating and permanent impact to birds and other wildlife along this stretch of the Bitterroot River corridor. Residential living units should not be allowed on the Old Hospital site. The natural and historic values along Bitterroot River corridor in Fort Missoula is a treasure that needs protection for all citizens to enjoy now and in future generations. The developer needs to find other ways of financing restoration of the historic hospital. Letter to Mary McCrea, May 11, 2022 To Mary McCrae <mccream@ci.missoula.mt.us> From Gerhard Knudsen and Jim Brown During the past fifteen years, Five Valleys Audubon Society has offered comment on nearly all land development proposals under the jurisdiction of Missoula County. Our interest in doing so is to reduce the impact of such activity on areas having valued avian habitat. In pursuing this objective, we have sought to engage in the early phases of the review process. Our focus has been to offer comment on the habitat values of a site and suggest means to mitigate impacts of a prospective development. In the end, we are hopeful that developers will then seek to integrate our suggestions into their ultimate plan of development. Development projects within the jurisdiction of the city rarely have the potential to affect valued avian environments. That being the case, we have not offered comment on such undertakings. The proposed Fort Missoula Commons, however, is a development within the purview of the city that will doubtlessly have an impact on bird habitat. Our interest in this project centers on its implications to adjoining riparian cottonwood and associated wetland habitat. Riparian areas are habitats occupying less than four percent of Montana’s land area. Significantly, they are used by more than 80 percent of the bird species found in the state during all or part of the year. No other habitat in the West supports a higher diversity of breeding birds. Riparian habitat adjoining the proposed Fort Missoula Commons development lies within the Clark Fork River-Grass Valley Important Bird Area. An international conservation effort, the Important Bird Area (IBA) program is aimed at identifying locations with healthy bird populations and encouraging conservation measures that protect the underlying habitat. Extensive data collected by the Five Valleys Audubon Society documented 246 bird species within the IBA. That is more than half the number of species recorded for the entire state. Thirteen of the species were breeding populations of birds having a high conservation priority. Due to the large number of Lewis’s Woodpeckers, a species of special conservation concern, the status of the IBA was raised to one of “continental significance.” Importantly, the land development being proposed for Fort Missoula lies within a migration corridor in the Missoula Valley, a fact well-established by repeated bird surveys within the IBA. Recent scientific studies conducted by Project Night Flight Inc. further attest to this fact. As part of that research, more than 50 bioacoustic recorders have been located throughout the Bitterroot Valley and into the south end of the Missoula Valley. The research focus is birds that migrate during the night and then land in “stopover” habitat each day to rest and feed. When migrating at night, birds frequently give calls, possibly to echolocate, communicate with other birds or maintain flock spacing and cohesion. Acoustic monitoring technology records those calls during the entire migration period and subsequent analysis determines the species involved and their numbers. Results of the Night Flight research reveal that, during the fall, thousands of birds comprising many species migrate at night though these valleys and stop over during the day. Bird numbers are greatest where valleys narrow at pinch points such as the juncture of the Missoula and Bitterroot Valleys. Bird use documented on the adjoining Knife River Pond area further affirms that the general area is on a migratory bird pathway. During the past several years, 227 bird species have been observed by birders submitting records to the Cornell University Lab of Ornithology’s “eBird” database. The pond area is considered a birding “hotspot” and its species count is among the highest in the state. The Knife River Ponds and neighboring University of Montana land comprise a rich natural resource and offer an opportunity to become a treasured natural area easily accessible to Missoula's citizens. Along with the ponds, a natural area would include adjoining University property that supports the University's Bird Ecology Lab, native plant garden, undeveloped grassland and riparian habitat. The natural area concept that is now being explored envisions the area being managed to protect its significant natural values for the education and enjoyment of Missoula's citizens. It is worthy of note that the area would include valued riparian habitat abutting land where the Fort Missoula Commons project would be sited. It is the riparian environment found on Slevin’s Island, one of Missoula’s most popular birding areas and where a rich diversity of bird species has been documented. As the Missoula community deliberates on the proposed Fort Missoula Commons development, it seems imperative that the dialogue address its implications to the area’s natural values as well as current and future uses of adjoining property. Our interest at this point is to promote that dialogue and offer some background about the habitat values of the area and provide a broader context to the development. We would be particularly interested in discussions regarding mitigative action needed to limit the impact of the planned development on adjoining avian habitat. If you feel it would be helpful, we would welcome the opportunity to meet with you and discuss our concerns in further detail. Jim Brown Five Valleys Audubon Conservation Chair

    Jim Brown asked 9 months ago

     

  • Share Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivable(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves, It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving, 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a laymen’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC) Given the above, when this private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide unilaterally and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. ————————— Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission, Updated 4/30/23. Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and Vice President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years.  I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit.  I should like to address the North of the Border (NOTB)-Wolf development proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations.   1. Background.   The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership.   As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District aproached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident.   I will agree with NOTB-Wolf to a point on one matter, and that is their note of the present need for attention to building repair in the hospital. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public property favor.   Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD).   NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6)   There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC.   The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.)   To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of a nebulous “greater good.” This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well.  2. Proposal mechanics.  Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s  perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application.  Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD.   Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Given the above, when a private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources.   Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91)  And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented.   On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191)   As NOTB-Wolf was informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that this project will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever.   But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects.  Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue.   One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula.   Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of such and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that.   I will caveat myself and make one observation  on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost.   I would furthermore in the application' note the qualification “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District.  Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area.  Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another will be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust application had more total funding available than the total amount requested in the grant applications.  Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9)   Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above:   * No historic district or park runs at a state of 100% repair and efficiency.  * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and,   * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control.  Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt, and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing.  Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter.   Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal.  I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter.   To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented.   Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivable(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves, It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving, 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a laymen’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC) Given the above, when this private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide unilaterally and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. ————————— Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission, Updated 4/30/23. Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and Vice President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years.  I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit.  I should like to address the North of the Border (NOTB)-Wolf development proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations.   1. Background.   The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership.   As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District aproached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident.   I will agree with NOTB-Wolf to a point on one matter, and that is their note of the present need for attention to building repair in the hospital. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public property favor.   Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD).   NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6)   There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC.   The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.)   To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of a nebulous “greater good.” This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well.  2. Proposal mechanics.  Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s  perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application.  Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD.   Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Given the above, when a private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources.   Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91)  And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented.   On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191)   As NOTB-Wolf was informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that this project will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever.   But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects.  Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue.   One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula.   Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of such and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that.   I will caveat myself and make one observation  on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost.   I would furthermore in the application' note the qualification “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District.  Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area.  Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another will be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust application had more total funding available than the total amount requested in the grant applications.  Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9)   Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above:   * No historic district or park runs at a state of 100% repair and efficiency.  * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and,   * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control.  Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt, and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing.  Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter.   Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal.  I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter.   To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented.   Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in.  on Facebook Share Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivable(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves, It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving, 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a laymen’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC) Given the above, when this private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide unilaterally and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. ————————— Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission, Updated 4/30/23. Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and Vice President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years.  I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit.  I should like to address the North of the Border (NOTB)-Wolf development proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations.   1. Background.   The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership.   As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District aproached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident.   I will agree with NOTB-Wolf to a point on one matter, and that is their note of the present need for attention to building repair in the hospital. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public property favor.   Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD).   NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6)   There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC.   The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.)   To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of a nebulous “greater good.” This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well.  2. Proposal mechanics.  Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s  perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application.  Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD.   Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Given the above, when a private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources.   Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91)  And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented.   On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191)   As NOTB-Wolf was informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that this project will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever.   But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects.  Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue.   One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula.   Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of such and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that.   I will caveat myself and make one observation  on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost.   I would furthermore in the application' note the qualification “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District.  Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area.  Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another will be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust application had more total funding available than the total amount requested in the grant applications.  Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9)   Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above:   * No historic district or park runs at a state of 100% repair and efficiency.  * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and,   * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control.  Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt, and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing.  Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter.   Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal.  I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter.   To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented.   Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivable(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves, It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving, 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a laymen’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC) Given the above, when this private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide unilaterally and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. ————————— Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission, Updated 4/30/23. Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and Vice President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years.  I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit.  I should like to address the North of the Border (NOTB)-Wolf development proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations.   1. Background.   The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership.   As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District aproached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident.   I will agree with NOTB-Wolf to a point on one matter, and that is their note of the present need for attention to building repair in the hospital. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public property favor.   Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD).   NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6)   There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC.   The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.)   To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of a nebulous “greater good.” This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well.  2. Proposal mechanics.  Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s  perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application.  Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD.   Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Given the above, when a private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources.   Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91)  And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented.   On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191)   As NOTB-Wolf was informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that this project will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever.   But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects.  Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue.   One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula.   Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of such and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that.   I will caveat myself and make one observation  on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost.   I would furthermore in the application' note the qualification “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District.  Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area.  Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another will be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust application had more total funding available than the total amount requested in the grant applications.  Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9)   Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above:   * No historic district or park runs at a state of 100% repair and efficiency.  * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and,   * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control.  Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt, and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing.  Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter.   Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal.  I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter.   To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented.   Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in.  on Twitter Share Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivable(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves, It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving, 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a laymen’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC) Given the above, when this private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide unilaterally and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. ————————— Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission, Updated 4/30/23. Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and Vice President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years.  I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit.  I should like to address the North of the Border (NOTB)-Wolf development proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations.   1. Background.   The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership.   As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District aproached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident.   I will agree with NOTB-Wolf to a point on one matter, and that is their note of the present need for attention to building repair in the hospital. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public property favor.   Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD).   NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6)   There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC.   The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.)   To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of a nebulous “greater good.” This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well.  2. Proposal mechanics.  Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s  perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application.  Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD.   Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Given the above, when a private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources.   Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91)  And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented.   On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191)   As NOTB-Wolf was informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that this project will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever.   But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects.  Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue.   One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula.   Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of such and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that.   I will caveat myself and make one observation  on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost.   I would furthermore in the application' note the qualification “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District.  Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area.  Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another will be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust application had more total funding available than the total amount requested in the grant applications.  Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9)   Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above:   * No historic district or park runs at a state of 100% repair and efficiency.  * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and,   * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control.  Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt, and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing.  Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter.   Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal.  I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter.   To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented.   Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivable(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves, It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving, 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a laymen’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC) Given the above, when this private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide unilaterally and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. ————————— Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission, Updated 4/30/23. Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and Vice President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years.  I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit.  I should like to address the North of the Border (NOTB)-Wolf development proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations.   1. Background.   The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership.   As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District aproached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident.   I will agree with NOTB-Wolf to a point on one matter, and that is their note of the present need for attention to building repair in the hospital. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public property favor.   Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD).   NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6)   There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC.   The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.)   To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of a nebulous “greater good.” This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well.  2. Proposal mechanics.  Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s  perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application.  Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD.   Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Given the above, when a private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources.   Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91)  And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented.   On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191)   As NOTB-Wolf was informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that this project will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever.   But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects.  Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue.   One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula.   Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of such and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that.   I will caveat myself and make one observation  on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost.   I would furthermore in the application' note the qualification “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District.  Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area.  Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another will be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust application had more total funding available than the total amount requested in the grant applications.  Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9)   Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above:   * No historic district or park runs at a state of 100% repair and efficiency.  * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and,   * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control.  Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt, and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing.  Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter.   Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal.  I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter.   To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented.   Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in.  on Linkedin Email Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivable(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves, It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving, 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a laymen’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC) Given the above, when this private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide unilaterally and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. ————————— Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission, Updated 4/30/23. Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and Vice President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years.  I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit.  I should like to address the North of the Border (NOTB)-Wolf development proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations.   1. Background.   The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership.   As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District aproached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident.   I will agree with NOTB-Wolf to a point on one matter, and that is their note of the present need for attention to building repair in the hospital. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public property favor.   Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD).   NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6)   There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC.   The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.)   To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of a nebulous “greater good.” This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well.  2. Proposal mechanics.  Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s  perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application.  Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD.   Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Given the above, when a private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources.   Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91)  And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented.   On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191)   As NOTB-Wolf was informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that this project will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever.   But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects.  Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue.   One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula.   Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of such and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that.   I will caveat myself and make one observation  on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost.   I would furthermore in the application' note the qualification “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District.  Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area.  Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another will be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust application had more total funding available than the total amount requested in the grant applications.  Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9)   Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above:   * No historic district or park runs at a state of 100% repair and efficiency.  * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and,   * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control.  Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt, and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing.  Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter.   Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal.  I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter.   To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented.   Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivable(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves, It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving, 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a laymen’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC) Given the above, when this private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide unilaterally and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. ————————— Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission, Updated 4/30/23. Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and Vice President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years.  I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit.  I should like to address the North of the Border (NOTB)-Wolf development proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations.   1. Background.   The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership.   As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District aproached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident.   I will agree with NOTB-Wolf to a point on one matter, and that is their note of the present need for attention to building repair in the hospital. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public property favor.   Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD).   NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6)   There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC.   The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.)   To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of a nebulous “greater good.” This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well.  2. Proposal mechanics.  Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s  perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application.  Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD.   Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Given the above, when a private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources.   Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91)  And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented.   On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191)   As NOTB-Wolf was informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that this project will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever.   But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects.  Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue.   One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula.   Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of such and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that.   I will caveat myself and make one observation  on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost.   I would furthermore in the application' note the qualification “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District.  Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area.  Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another will be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust application had more total funding available than the total amount requested in the grant applications.  Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9)   Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above:   * No historic district or park runs at a state of 100% repair and efficiency.  * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and,   * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control.  Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt, and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing.  Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter.   Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal.  I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter.   To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented.   Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in.  link

    Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivable(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves, It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving, 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a laymen’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC) Given the above, when this private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide unilaterally and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. ————————— Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission, Updated 4/30/23. Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and Vice President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years.  I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit.  I should like to address the North of the Border (NOTB)-Wolf development proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations.   1. Background.   The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership.   As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District aproached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident.   I will agree with NOTB-Wolf to a point on one matter, and that is their note of the present need for attention to building repair in the hospital. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public property favor.   Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD).   NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6)   There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC.   The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.)   To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of a nebulous “greater good.” This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well.  2. Proposal mechanics.  Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s  perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application.  Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD.   Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Given the above, when a private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources.   Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91)  And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented.   On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191)   As NOTB-Wolf was informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that this project will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever.   But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects.  Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue.   One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula.   Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of such and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that.   I will caveat myself and make one observation  on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost.   I would furthermore in the application' note the qualification “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District.  Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area.  Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another will be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust application had more total funding available than the total amount requested in the grant applications.  Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9)   Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above:   * No historic district or park runs at a state of 100% repair and efficiency.  * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and,   * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control.  Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt, and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing.  Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter.   Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal.  I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter.   To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented.   Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivable(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves, It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving, 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a laymen’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC) Given the above, when this private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide unilaterally and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. ————————— Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission, Updated 4/30/23. Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and Vice President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years.  I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit.  I should like to address the North of the Border (NOTB)-Wolf development proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations.   1. Background.   The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor nonprofit, assumed use of the building until present sale and ownership.   As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District aproached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident.   I will agree with NOTB-Wolf to a point on one matter, and that is their note of the present need for attention to building repair in the hospital. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2023 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public property favor.   Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD).   NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6)   There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC.   The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area housing heritage, educational, recreational, governmental and some light office park needs. If it is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.)   To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of a nebulous “greater good.” This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well.  2. Proposal mechanics.  Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s  perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application.  Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD.   Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of these initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Given the above, when a private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources.   Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist work and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91)  And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented.   On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children. (190-191)   As NOTB-Wolf was informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that this project will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever.   But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects.  Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue.   One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula.   Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of such and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that.   I will caveat myself and make one observation  on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultative that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost.   I would furthermore in the application' note the qualification “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District.  Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area.  Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another will be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust application had more total funding available than the total amount requested in the grant applications.  Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up window exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9)   Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know. Four immediate points on the above:   * No historic district or park runs at a state of 100% repair and efficiency.  * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and,   * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control.  Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt, and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency were ongoing.  Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild, but securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter.   Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf proposal.  I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter.   To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented.   Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. 

    TateJones2 asked 5 months ago

     

  • Share (Corrected version, 2/1/24 - previous had formatting errors inserted by autocorrect plus unintended resubmission from last soring) Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border’s (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivabl(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves. It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving. Given the reality that the Historic District agencies and their colleagues have already been diverted from their core mission and compelled to spend considerable time and resources to deal with a proposal that should have been deterred by existing planning and zoning, this is an especially gratuitous addition. 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon-backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2024 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area comprising heritage, educational, recreational, governmental and some light office park needs. If such is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of the previous unsuccessful initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC). Given the above, when any private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist uwork and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children.” (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultation was told that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up windows exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know from 27 years of experience at Fort Missoula. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency over to-date intractable cleanup issues were ongoing, and appear to offer engagement for the next couple of generations. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild. Securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf adversarial redesign proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide such unilaterally to benefit FMC and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and physically segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. on Facebook Share (Corrected version, 2/1/24 - previous had formatting errors inserted by autocorrect plus unintended resubmission from last soring) Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border’s (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivabl(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves. It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving. Given the reality that the Historic District agencies and their colleagues have already been diverted from their core mission and compelled to spend considerable time and resources to deal with a proposal that should have been deterred by existing planning and zoning, this is an especially gratuitous addition. 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon-backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2024 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area comprising heritage, educational, recreational, governmental and some light office park needs. If such is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of the previous unsuccessful initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC). Given the above, when any private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist uwork and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children.” (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultation was told that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up windows exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know from 27 years of experience at Fort Missoula. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency over to-date intractable cleanup issues were ongoing, and appear to offer engagement for the next couple of generations. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild. Securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf adversarial redesign proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide such unilaterally to benefit FMC and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and physically segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. on Twitter Share (Corrected version, 2/1/24 - previous had formatting errors inserted by autocorrect plus unintended resubmission from last soring) Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border’s (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivabl(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves. It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving. Given the reality that the Historic District agencies and their colleagues have already been diverted from their core mission and compelled to spend considerable time and resources to deal with a proposal that should have been deterred by existing planning and zoning, this is an especially gratuitous addition. 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon-backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2024 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area comprising heritage, educational, recreational, governmental and some light office park needs. If such is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of the previous unsuccessful initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC). Given the above, when any private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist uwork and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children.” (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultation was told that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up windows exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know from 27 years of experience at Fort Missoula. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency over to-date intractable cleanup issues were ongoing, and appear to offer engagement for the next couple of generations. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild. Securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf adversarial redesign proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide such unilaterally to benefit FMC and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and physically segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. on Linkedin Email (Corrected version, 2/1/24 - previous had formatting errors inserted by autocorrect plus unintended resubmission from last soring) Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border’s (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivabl(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves. It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving. Given the reality that the Historic District agencies and their colleagues have already been diverted from their core mission and compelled to spend considerable time and resources to deal with a proposal that should have been deterred by existing planning and zoning, this is an especially gratuitous addition. 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon-backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2024 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area comprising heritage, educational, recreational, governmental and some light office park needs. If such is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of the previous unsuccessful initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC). Given the above, when any private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist uwork and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children.” (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultation was told that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up windows exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know from 27 years of experience at Fort Missoula. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency over to-date intractable cleanup issues were ongoing, and appear to offer engagement for the next couple of generations. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild. Securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf adversarial redesign proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide such unilaterally to benefit FMC and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and physically segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in. link

    (Corrected version, 2/1/24 - previous had formatting errors inserted by autocorrect plus unintended resubmission from last soring) Statement of Tate Jones, President, Northern Rockies Heritage Center, Fort Missoula; Re: Post Hospital Development Proposal, Missoula Historic Preservation Commission/Missoula City Council, Updated 1/31/24 Good morning . By way of introduction I am President of the Northern Rockies Heritage Center (NRHC) and Executive Director of the Rocky Mountain Museum of Military History (RMMMH), both at Fort Missoula, and the incoming President of the Museums Association of Montana. I have assisted in various historic preservation capacities at Fort Missoula now for about 27 years. I should also note that NRHC is a Congressionally-chartered nonprofit organization, mandated by Federal statute to receive, own and maintain Heritage Hall, Officers Row, the parade grounds, and other buildings and acreage at Fort Missoula in their historic 1910-14 setting and to use those resources for the public benefit. I should like to address the North of the Border’s (NOTB - and for all practical purposes synonymous with its also Denver, Colo.—based twin, FAE-Wolf) adversarial redesign proposal first through the background of the hospital parcel, second through the proposal's mechanics, and finally through the proposal's impacts on the Fort landscape and neighboring organizations. But to preface, I will note this appeal of NOTB- Wolf’s application, denied unanimously by the City Historic Preservation Commission, is in large part based on NOTB-Wolf’s assertion that “conceivabl(y) some members of the HPC had undisclosed conflicts of interest, or possible improper ex parte conflicts…” (Communication to Missoula City Council, 6/1/23). These allusions to such on the part of HPC members and Fort Missoula Commons opponents have now stood for eight months unsubstantiated by any presented evidence, and it is most unfair that those parties have not been able to defend themselves. It remains to be seen if NOTB-Wolf will present any real evidence or if the above is simply an exercise in political hit-and-run driving. Given the reality that the Historic District agencies and their colleagues have already been diverted from their core mission and compelled to spend considerable time and resources to deal with a proposal that should have been deterred by existing planning and zoning, this is an especially gratuitous addition. 1. Background - an unfortunate past and present record of Post Hospital stewardship, and a “cure”worse than the disease. The Fort Missoula Post Hospital was constructed as part of the Senator Joseph Dixon-backed “New Post” initiative of 1910-14, and subsequently the epicenter for the World War I influenza epidemic in Western Montana. By 1963 the Army was seeking to downsize its holdings at the Fort, and for the sum of one dollar transferred the building and grounds to the Missoula Women's Club, which subsequently transferred the package to the Western Mt. Youth Guidance Center. By the 1970's the Western Montana Mental Health Center (WMMHC), a Federal and state-chartered medical contractor, assumed use of the building until present sale and ownership. As WMMHC sought to exit the structure in the late 2010's, NRHC made several written inquiries to the WMMHC staff and board seeking to open discussion as to the structure's disposition. No reply of substance was ever received. In November 2019 representatives of the Fort Missoula Historic District approached the Missoula County Commissioners in their capacity, with the other BCC's of western Montana as board oversight of the WMMHC, to address the matter constructively. They declined to take any direct action, and said, curiously with no organizational footing I can discern, that the matter rested with the city. The results of the BCC's lack of action are now evident. I will agree with NOTB-Wolf to a degree on one matter, and that is their note of the present need for attention to building repair in the hospital - and I would also emphasize their responsibility to have money in hand to do such prior to acquiring property, a common- sense rule most of the rest of us live by. I would note for the record that the owner of the building for nearly fifty years was the WMMHC. In that context I believe that the matter of how a building transferred from the Department of Defense for public benefit in 1963 ended up being subject to private development in 2024 is certainly worthy of some hard organizational oversight and scrutiny, and that WMMHC's trusteeship of the building and subsequent sale to the private sector should certainly be taken into account the next time WMMHC seeks a public policy favor. Proceeding to the present matter, I will address the present zoning shared by NRHC and the hospital property. I will recall that when a family member chaired the city Board of Adjustment, he made it clear that variances and zoning changes only went through when there was consensus for such from the neighboring surrounding landowners. As of today there is no such consensus for a zoning change from the largest neighboring and surrounding landowner, NRHC. Neither have the other two primary private historic preservation agency representatives, the board of RMMMH and the board of the Friends of the Historical Museum at Fort Missoula (HMFM) provided such consensus. Finally, to date I have seen no evidence of support for a zoning change from any landowning organization in the Fort Missoula Historic District (HD). NRHC is happy to cite support for the above by citing the 2/19/21 Tres Birds consultation sponsored by Wolf-NOTB. As per the report, Fort resident organizations indicated no support for housing or bar construction. (6) There has been no acknowledgment from NOTB-Wolf that the needs and mandate of NRHC need to be accommodated; long-distance discussions with the project consultants and pro forma contacts have largely resulted in NOTB-Wolf essentially telling neighboring landowners what will happen. That is unacceptable to NRHC. The zoning and planning at Fort Missoula evolved over a fifty-year period with the goal of creating an area comprising heritage, educational, recreational, governmental and some light office park needs. If such is now considered disposable we might have saved ourselves an overwhelming amount of time, effort, and money, and as of 1975 simply sectioned out the complex and planted “LLC, Set Up Here With Whatever” signs. But if the zoning is still to guide planning for the campus, then it was incumbent on NOTB-Wolf to know the zoning prior, adjust their plans accordingly, and if what they sought was not feasible with their resources, move on elsewhere. (By way of personal experience, my family has been active in handling and advising upon real estate transactions since the early 1960’s, and the business model of buying first and expecting a rezone second is entirely unfamiliar to us.) To now inaugurate a bidding war for Fort Missoula zoning will have severe consequences for the future of the campus; there will always be one more LLC willing to buy and subdivide in the name of whatever cause du jour enjoys current popularity. This proposal legitimizes zoning by auction as de facto land planning, and NRHC finds that unacceptable as well. 2. Proposal mechanics - why replicating Paxson Plaza at Fort Missoula is really not a “historic preservation project.” Others more qualified are addressing the architectural details of the proposal (though I can offer a layman’s perspective that it seems a faithful re-creation of a Reagan-era Northern Virginia suburban town center), NRHC wishes to focus more on the rationales and expanse of the application. Starting with the 3/2/23 op-ed claim that preservation advocates have “never presented a viable plan,” I would refer to the above record of HD agencies trying to deal with WMMHC and its BCC oversight. On top of that, neither NRHC nor any other component of the historic preservation community has the time or resources to spend drawing up plans for buildings we do not own, do not have authority over, and do not have access to. We are again compelled to rely upon existing zoning constraints to protect the HD. Turning to NOTB-Wolf’s brochure assertion “the point of being able to save the building is fast approaching” (3) NRHC notes that is the 3rd WGM-accompanied attempt since the 1990’s to introduce residential development to the Fort, that all of the previous unsuccessful initiatives required overwhelming commercial and/or residential overbuild, and that its high time to acknowledge that private land speculation companies and their consultants are centered in the historic preservation field the same way Smurfit-Stone’s primary mandate was ecosystem protection. Finally FAE\NOTB’s cited experience in undertaking high profile and sensitive projects through completion of the Rattlesnake Basecamp development might be reexamined in lieu of their active litigation with RB’s contractor over “significant problems developed over the course of…work.” (Missoula 4th Judicial District, Cause No. DV-42-2023-0001183-BC). Given the above, when any private land speculation company yells “stampede!” on historic preservation, NRHC sits back and declines to join the herd. Self-reporting on viability does not cut it for us here, and as will be noted again below, the HD agencies have by now acquired significant internal expertise in a variety of HPC-overseen building restoration projects funded by a wide variety of private and public sources. Dealing with the commercial overbuild, the application claims “the Fort is lacking in services...presently citizens using the fort must leave the area to access needed services...the Fort lacks services to support the employees who work in the Historic buildings or patrons of the regional park. Childcare, personal improvement services, restaurant or food services, salons, professional services, artist uwork and sales space, residential support services...are being proposed...You can get a bag of fried donuts as lunch between soccer or baseball games, but not a healthy meal for your family at the fort.” (9, 190-91) And so comes the solution looking for a problem. In my 27 years at Fort Missoula the absence of retail and food/beverage services has never been mentioned in various planning processes a problem worthy of discussion. It is generally expected that picnic events, catering and food trucks are adequate to the need, and if more services are required, these are offered by many fine and qualified establishments less than a two-minute drive away on Brooks. On alcohol, none of the landowning organizations in the Historic District has ever expressed a desire to get into the beverage business, and private events serving alcohol subject to state regulations are also adequate to the fort's needs. NRHC is concerned that any bar setting up in the proposed commercial buildings could easily follow the route of some Missoula operations from high-end lounge to drink-to-get-drunk bar, and that would be highly incompatible with the family atmosphere the HD organizations have cultivated for a half-century. We would strongly urge safeguards against such be implemented. On the housing matter, the application notes “the housing is being proposed to deal with the housing crisis in the city...the fort would also be a strong draw for citizens looking for a place to raise their children.” (190-191) As NOTB-Wolf was clearly informed by NRHC two years ago, housing is the red line for the preservationist community at Fort Missoula; a residential component bequeaths residential problems onto the Fort and is incompatible with a true public commons dedicated to the uses I mentioned previously. In addition, I would call the claim that that inserting Econolodge architecture into Fort Missoula will address housing deficits tokenism, but I really would not want to assign it that high a rank. I have seen housing market shortages and surpluses come and go over a lifetime in Missoula. I am not a housing specialist, and have no general solutions to offer to present conditions other than to note they will likely by default resolved in the same way they always have, by the adage that no bull - or bear - market goes on forever. But, I am enough of a historic site administrative specialist to firmly state that it is not the job or mandate of park, recreation heritage and historic district-designated lands to solve housing market shortages, any more than it was the duty of the national forests, parks, and wilderness areas to maintain the wood products industry at 1970's levels by redoubling industrial logging operations within their boundaries. In both cases the main issues will remain unaddressed while adding on highly negative side effects. Deserving response as well is NOTB-Wolf’s assertion in its brochure that a proposal benefit will be “increased foot traffic to Fort Missoula museums and attractions.” (6) We have heard this old chestnut before, notably during the runs of the 1990’s Divot Development/internment site plan and the c. 2002 seniors’ home initiative for the hospital parcel. In both cases, the proponents (universally individuals with no credentials in administering museums and/or historic sites) claimed increased volunteer participation and visitation would be peripheral benefits. Volunteer support - if my 27 years of experience in museum administration counts for anything - has nothing to do with directly adjacent residence; RMMMH hosts volunteers from Alberton, Lolo, Bonner, and elsewhere. Growing visitation is the responsibility of the Historic District agencies, and we handle it well. The Historic District by the most recent estimate indicates 50,000 visitors per annum. The NOTB-Wolf proposal is definitely not coming to our rescue. One more note on this – the Historic District was not designed and is not intended as a free-range playground where neighboring children can simply be turned loose. That will likely not bode well for the historic structures under the HD's care, and some of the machinery on display is simply not of the type designed for safe independent play. The open nature of the Historic District is possible because it is largely buffered from residential areas and more easily managed due to no residential component. On the East Coast, a similar combined historical park is usually surrounded by chain link fence and controlled access, and inserting a small town into the complex will likely hasten that day for Fort Missoula. Furthermore, I will note the application's assertion that at the fort, “nonprofit and government offices occupy the buildings but do not fund tax growth needed for city investment or infrastructure.” (7) I will recall that the basis for the nonprofit model is tax exemption – under strict state and federal oversight, nonprofits are removed from the tax system with the expectation that they will reinvest their revenues into their public service missions. The HD agencies have in the last half-century posted an admirable record of s and the notion that somehow they should now be mandated to fund basic governmental functions is a new one to me. I will note that according to Federal statistics, the arts and culture sector in Montana- which includes the HD agencies – as of pre-pandemic 2019 injected $1.8 billion into the Montana economy, comprised 3.4% of the state's GDP, and created 15,811 jobs with compensation of $939 million. Its safe to assume Missoula saw a fair chunk of that. I will caveat myself and make one note on project design. It does not engender confidence in the larger project if NOTB-Wolf intends to start out by demolishing the CCC garage, the restoration of which would be a far simpler project, and I question the rather inflated estimates given for doing so. That comes from experience – NRHC restored four generally similar period garages that were formally condemned when it took over the property, and RMMMH initially in its first architectural consultation was told that the CCC District Headquarters Building was beyond salvage. It is now entering its 23rd year as the primary display building for RMMMH. Both these projects were completed at reasonable cost. I would furthermore in the application's note that “the phases may overlap.” (8) I would urge in the worst case the commission mandate that all restoration work on the historic structures be completed prior to any commercial or residential overbuild, so as to avoid the ultimate tag line forever attached to the Mercantile project - “things happen.” They do indeed. The Mercantile project went from one of historic preservation with a commercial component to a commercial project with a very limited preservation component because the initial backer passed on. People and commitments die, zoning does not, and for that reason NRHC places its faith in the existing zoning within the Historic District. Referring to the proposed Community Building, NOTB-Wolf states “we cannot guarantee the ability to provide this amenity unconditionally.” (8) NRHC has for the last fifteen years provided community center services at Heritage Hall to Missoula and its visitors, and our only conditions are safety measures and a reasonable charge for provision of service - which NRHC promptly reinvests in maintenance and upkeep of the New Post area. Correction is also due NOTB-Wolf’s brochure assertion that the proposed commercial-residential overbuild “can generate the necessary income to pay for the hospital’s rehabilitation so that we do not take historic grant opportunities away from smaller communities that need this limited capital.” (5) Red herring season is now in full swing. During my two decade plus career in museum administration I have applied for, evaluated, and designed numerous grant proposals at the local, state, and federal level. I have also served two terms on the Montana State Cultural Trust evaluation committee, and I am commencing a third. Not once have I heard a complaint to the effect that Missoula’s applications were starving the rest of the state. At any given moment many state projects will be attempting to match up with available specialized grant funds on a merit basis, and to try to discern any undue demands for funds by one locality or another would be a nebulous and unrewarding exercise. And for the record the latest round of State Cultural Trust applicants had more total funding available than the total amount of grant applications. Finally in this section I will note the application's comment on the state of the HD: “The Fort has fallen into various levels of disrepair over the decades with some restoration but as a whole it is still in decline from its period of significance from 1877-1947. The roads are falling apart (more on that later) peeling paint is a feature of many structures, boarded up windows exist on more than one building and site. This project could be the spark that brings the the community back to the Fort to support revitalization, embrace its potential history with the only thing lost being its previous decline.” (8-9) Quite a conclusion likely derived from a highly selective twenty-second walk from the hospital over to the UM-owned nurses quarters, and untethered to any reality I know from 27 years of experience at Fort Missoula. Four immediate points on the above: * No historic district or park runs at a state of 100% repair and efficiency. * Much of NOTB-Wolf’s assertion cites the condition of HMFM’s Forestry Area, which since 1974 has interpreted through demonstration the history of the logging industry - and that requires machinery and raw materials in a job-site setting. * A minor amount of needed improvement emits from non-HMFM/RMMMH /NRHC areas in legacy public ownership, and, * The three main Historic District agencies have continuously pressured those owners to take remedial action - and our lines are always open re. ideas on how to motivate the unmotivated bureaucracies of agencies we do not control. Furthermore, I would note by a conservative back-of-envelope calculation that combined investment into the HD and the park likely clocks in at about $52 million since 1974, and that the HD receives about 50,000 visitors a year. NRHC, RMMMH and HMFM are all members of the American Association for State and Local History as well as the Museums Association of Mt., and HMFM is accredited by the American Alliance of Museums. Fort Missoula, due to its role in the World War II internment of Italian and Japanese nationals, is recognized as an International Site of Conscience. Fort Missoula Regional Park has been awarded Silver Level Certification by the Sustainable SITES Initiative. 3. Historic landscape impacts - reversing a half century of community preservation effort to benefit a single private land speculation company. I will start out by noting that NRHC has been pleased to cooperate with the city in securing the general improvement of the Fort Missoula landscape. NRHC supported after genuine stakeholder collaboration the Regional Park, transferred water rights for park use, and recently supported city grant application for road improvements on Post Siding Rd. NRHC would ask the city to reciprocate by at least not approving development harmful to NRHC's interests. On a general environmental note, I would recall that until the 1970's, by retiree recollection, the fort used the Bitterroot River as a general dump for sewage and industrial waste. Until a comprehensive independent study is made of possible waste sites on the fort's riverbank, I would be very hesitant before starting to move earth and planting homesites upon it. I will recall that the past head of the Missoula Area Economic Development Corp. c. 2010 claiming that he had been assured everything had been cleaned up at the Smurfit Stone site. As of a couple of weeks ago, meetings with the federal Environmental Protection Agency over to-date intractable cleanup issues were ongoing, and appear to offer engagement for the next couple of generations. Turning to the matter of Fort roads, I will now point out that NRHC owns – unless we have been very misled by our transfer documents and governmental consults over two decades – Moe, part of Moss, and Sanders streets. We have endeavored to keep these formerly relatively lightly used institutional roads open to the public. We do not have a road department, and assistance from local government on this issue has been negligible. A quick view will show these roads are due for some major rebuild. Securing that has nothing to do with any actions outlined in this application, nor will this application provide any remedies. But if NRHC property is expected to bear the burden of increased construction, residential, and commercial traffic with accompanying liability at the expense of its infrastructure, NRHC will move rapidly to legally protect itself. And such actions may include posting as legally allowed the above streets as NRHC parking only and instituting towing zones. NRHC will move to foreclose endless extra car, RV boat and camper parking as affects so many Missoula streets, nor permit street residence by visitors who park in the summer and attempt to remain stationary through winter. Moreover, evaluators need to take a very hard look at the safety ramifications of inserting a small town equivalents’ traffic onto an already-overburdened 1930’s road system designed for moderate institutional use. The Historic District roads are presently shared by pedestrians, dog walkers, bicyclists, cars, and occasionally commercial trucks. This load has been increased by Regional Park usage, and the results are not altogether happy. The Historic District is presently grappling with speeding/reckless driving problems exacerbated by a lack of enforcement for same, and if the present rate of use accelerates probability dictates some of the above users are likely to meet with negative encounters. NRHC is of the firm opinion that the Fort’s infrastructure is not adequate to the NOTB-Wolf adversarial redesign proposal. Additionally, on roads under NRHC ownership NRHC would welcome assistance in bringing infrastructure up to standard for the present use regime - but will not provide such unilaterally to benefit FMC and will prohibit work intended to facilitate the Fort Missoula Commons adversarial redesign as presented. If affluent condominium owners are confronted with a daily drive over slag to access their residences, so be it. I would also note that the arborist consultation attached calls for action on the trees lining Moss and Sanders streets. Again, NRHC's transfer documents provided indicate that the south and western frontage along these streets is owned by NRHC to a small distance in from the streets, and NRHC reserves the right to manage its own vegetation. So NRHC would strongly urge NOTB-Wolf to obtain a resolution on that before proceeding with any action on this matter. To summarize and conclude, NRHC notes the previous projects that called for overbuild in the New Post area: early 1990's – bulldoze Officers Row and build minor league stadium; c. 1995 – convert Officers Row into low income housing complex, c. 2002 – large seniors’ home next to hospital; c. 2011 – residential detox center next to hospital. The precedent set and reaffirmed repeatedly by the HPC and other decision-makers is that all of these proposals were definitely in opposition to Fort planning intentions, and that the Fort remain a true public commons, open to the public and centering on heritage, recreational, governmental, and office park use. In further affirmation of that, NRHC, RMMMH and the Friends of HMFM are joined in resolution against further residential development at Fort Missoula, and stand in opposition to this application as presented. Fort Missoula Commons has received additional negative comment from the Montana State Historic Preservation office and a substantial number of individuals nationally and internationally. FAE-Wolf in turn has failed to show support from any member or organization of note from the Missoula history and historic preservation communities - a dubious exception being one commenter in the Missoulian who noted he had done some related work in the 1980’s, but neglected to mention his employment history with NOTB-Wolf contractor WGM. Furthermore, should this application proceed to approval, NRHC will utilize every right available to it as a landowner to fulfill its Congressional mandate and physically segregate our property and grounds from this activity. This is not our preferred option, but we will utilize it if compelled – and the application's proposed “connective tissue” (8) for Fort Missoula will end up looking more like a tourniquet. In summary, NRHC joins with the 31 other organizations of the Historic Fort Missoula Coalition to urge that the Missoula City Council disapprove Fort Missoula Commons as presented, and once and for all affirm that Fort Missoula is a significant and irreplaceable heritage site; that Fort Missoula is not a development corridor, and that organizations who cannot conform to existing Fort Missoula planning and zoning parameters need to take their plans elsewhere. To conclude, I will be the first to admit is not in my power alone to buy land and renovate buildings. But I have a small reputation for producing well-sourced exhibits on Fort Missoula history – others have clearly done greater work – and it is very much in my power to do so on the history of the Hospital parcel. NRHC is soon to open a visitor center in Heritage Hall, and we very much intend to cover this topic. So now would be a good time for all concerned individuals and organizations attached to this issue to take some time and reflect on what they want community members and visitors to read about them on a wall for the next couple of generations. The story to be told is still being written, and does have the potential to be one our descendants can take pride in.

    TateJones2 asked 5 months ago

     

  • Share I would like to take this opportunity to voice my opposition to the proposed development at the Fort Missoula Hospital. As the lead author of the recent expansion to the Fort Missoula National Register of Historic Places Nomination I will state unequivocally that this proposal will have an irreversible and lasting adverse impact to the historic qualities and values that make Fort Missoula eligible for the National Register. There are four historic resources that are part of this proposed development, the Post Hospital, the CCC Nurses Quarters, the CCC Garage and the Fort Missoula Historic Landscape. The Post Hospital is one of the grand buildings that represents the Fort Reconstruction Period of 1910 – 1912; it is a contributing structure to the historic district and in my professional opinion in the absence of a historic district it would be individually eligible for listing on the National Register. The proposed restoration and adaptive reuse of the Post Hospital is an idea that is long overdue and it is a vision that the Missoula community should support and appreciate. The restoration will be an expensive undertaking yet it is sorely needed. We should try to think outside of the box to find ways to help make this vision a reality. The CCC Nurses Quarters is a contributing structure to the Fort Historic District and it is reflective of the Civilian Conservation Corps building style that is scattered across our nation. Simple yet sturdy and functional in design, this building constructed by the CCC housed the nurses working at the Post Hospital. Like the Hospital, the restoration and adaptive reuse of this building is sorely needed and will be an expensive undertaking. I would caution that the preservation and restoration of both of these historic gems should follow the Secretary of the Interior’s Standards and Guidelines, I have not seen anything in any of the materials provided by the developers that the preservation efforts will utilize the highest preservation standards. The CCC Garage, located behind the CCC Nurses Quarters, has been suffering from benign neglect for decades and is in dire need of help. This building is also reflective of the architectural styles employed by the CCC at Fort Missoula as well across our nation. The garages behind Officer’s Row were also constructed by the CCC and they should serve as a blueprint for the restoration and preservation for this building. The plans for this building have changed and its future is not certain. Early plans called for deconstruction and removal; current plans envision moving the building. Either scenario would result in the building losing its National Register status. Fort Missoula also possesses a stunning and very visual historic landscape; the historic landscape is a contributing resource to the National Register Historic District. There are two historic eras’ from Fort Missoula’s lengthy and colorful past that are reflected in the landscape, the City Beautiful Movement and the Civilian Conservation Corps. During the Fort Reconstruction Period, the City Beautiful Movement swept the nation, the basic idea was that civic pride and appreciation of our public spaces would be enhanced by the landscape. There are elements of the City Beautiful Movement landscape that are still visible and scattered across the Fort. This includes buildings set back from streets, the curved streets, the presence of broad curved sidewalks meant to encourage a walkable environment, decorative lamp posts, wrought iron fences and the liberal use of a variety of plants to soften and humanize the appearance of a military installation. The proposed residential and commercial development would have a lasting and irreversible negative impact to the Fort Missoula Historic Landscape. I would also caution against the developer’s ideas for incorporating elements of the CCC style architecture in their residential and commercial plans. I am not opposed to new development at Fort Missoula, but I adamantly believe the development must be respectful and compatible with the historic values at Fort Missoula. There are two prime examples of modern development at Fort Missoula that reach these goals. The modern Bureau of Land Management offices are an example of compatible new construction in a historic district. The architects successfully created a modern government office building that blend into the Fort Missoula Historic District. The architects set the building back from the street scene, they employed berms and vegetation to break up the views of the building. They designed a short squat structure that utilized the distinctive red clay tiles and plain white adobe walls, architectural elements of the Spanish Mission style present in the tall stately buildings that gracefully line Officer’s Row. The Fort Missoula Regional Park is also an example of new development that is respectful of the Fort’s history. Missoula Parks and Recreation engaged in lengthy and successful conversations with the Fort stakeholders about the historic values of Fort Missoula. The resulting park is reflective of and honors the presence of the Civilian Conservation Corps and it is new development at the Fort that the Missoula community should consider with great pride. Any new development at Fort Missoula needs to look to both of these examples for guidance. I would also like to point out that the proposed development relies on using private property they do not own. Many of the streets at Fort Missoula are not public streets, they are privately owned and maintained at great expense by their owner. I am not an expert on city subdivision process by any measure but it seems to me that taking someone else’s private property for their private development should be hugely problematic. In summary, I would like to state I am not opposed to new development at Fort Missoula. The restoration of the Post Hospital is going to be an incredibly expensive and difficult undertaking and the Missoula community should embrace this idea and help find ways to make this vision happen. The currently proposed residential and commercial parts of this project will have a lasting and negative impact on the historic values that are so compelling at Fort Missoula. The current plans for development should be rejected because it is not compatible and respectful of the Fort’s history and because the current plans will result in an irreversible loss to buildings and resources included in the Fort Missoula National Register Historic District. on Facebook Share I would like to take this opportunity to voice my opposition to the proposed development at the Fort Missoula Hospital. As the lead author of the recent expansion to the Fort Missoula National Register of Historic Places Nomination I will state unequivocally that this proposal will have an irreversible and lasting adverse impact to the historic qualities and values that make Fort Missoula eligible for the National Register. There are four historic resources that are part of this proposed development, the Post Hospital, the CCC Nurses Quarters, the CCC Garage and the Fort Missoula Historic Landscape. The Post Hospital is one of the grand buildings that represents the Fort Reconstruction Period of 1910 – 1912; it is a contributing structure to the historic district and in my professional opinion in the absence of a historic district it would be individually eligible for listing on the National Register. The proposed restoration and adaptive reuse of the Post Hospital is an idea that is long overdue and it is a vision that the Missoula community should support and appreciate. The restoration will be an expensive undertaking yet it is sorely needed. We should try to think outside of the box to find ways to help make this vision a reality. The CCC Nurses Quarters is a contributing structure to the Fort Historic District and it is reflective of the Civilian Conservation Corps building style that is scattered across our nation. Simple yet sturdy and functional in design, this building constructed by the CCC housed the nurses working at the Post Hospital. Like the Hospital, the restoration and adaptive reuse of this building is sorely needed and will be an expensive undertaking. I would caution that the preservation and restoration of both of these historic gems should follow the Secretary of the Interior’s Standards and Guidelines, I have not seen anything in any of the materials provided by the developers that the preservation efforts will utilize the highest preservation standards. The CCC Garage, located behind the CCC Nurses Quarters, has been suffering from benign neglect for decades and is in dire need of help. This building is also reflective of the architectural styles employed by the CCC at Fort Missoula as well across our nation. The garages behind Officer’s Row were also constructed by the CCC and they should serve as a blueprint for the restoration and preservation for this building. The plans for this building have changed and its future is not certain. Early plans called for deconstruction and removal; current plans envision moving the building. Either scenario would result in the building losing its National Register status. Fort Missoula also possesses a stunning and very visual historic landscape; the historic landscape is a contributing resource to the National Register Historic District. There are two historic eras’ from Fort Missoula’s lengthy and colorful past that are reflected in the landscape, the City Beautiful Movement and the Civilian Conservation Corps. During the Fort Reconstruction Period, the City Beautiful Movement swept the nation, the basic idea was that civic pride and appreciation of our public spaces would be enhanced by the landscape. There are elements of the City Beautiful Movement landscape that are still visible and scattered across the Fort. This includes buildings set back from streets, the curved streets, the presence of broad curved sidewalks meant to encourage a walkable environment, decorative lamp posts, wrought iron fences and the liberal use of a variety of plants to soften and humanize the appearance of a military installation. The proposed residential and commercial development would have a lasting and irreversible negative impact to the Fort Missoula Historic Landscape. I would also caution against the developer’s ideas for incorporating elements of the CCC style architecture in their residential and commercial plans. I am not opposed to new development at Fort Missoula, but I adamantly believe the development must be respectful and compatible with the historic values at Fort Missoula. There are two prime examples of modern development at Fort Missoula that reach these goals. The modern Bureau of Land Management offices are an example of compatible new construction in a historic district. The architects successfully created a modern government office building that blend into the Fort Missoula Historic District. The architects set the building back from the street scene, they employed berms and vegetation to break up the views of the building. They designed a short squat structure that utilized the distinctive red clay tiles and plain white adobe walls, architectural elements of the Spanish Mission style present in the tall stately buildings that gracefully line Officer’s Row. The Fort Missoula Regional Park is also an example of new development that is respectful of the Fort’s history. Missoula Parks and Recreation engaged in lengthy and successful conversations with the Fort stakeholders about the historic values of Fort Missoula. The resulting park is reflective of and honors the presence of the Civilian Conservation Corps and it is new development at the Fort that the Missoula community should consider with great pride. Any new development at Fort Missoula needs to look to both of these examples for guidance. I would also like to point out that the proposed development relies on using private property they do not own. Many of the streets at Fort Missoula are not public streets, they are privately owned and maintained at great expense by their owner. I am not an expert on city subdivision process by any measure but it seems to me that taking someone else’s private property for their private development should be hugely problematic. In summary, I would like to state I am not opposed to new development at Fort Missoula. The restoration of the Post Hospital is going to be an incredibly expensive and difficult undertaking and the Missoula community should embrace this idea and help find ways to make this vision happen. The currently proposed residential and commercial parts of this project will have a lasting and negative impact on the historic values that are so compelling at Fort Missoula. The current plans for development should be rejected because it is not compatible and respectful of the Fort’s history and because the current plans will result in an irreversible loss to buildings and resources included in the Fort Missoula National Register Historic District. on Twitter Share I would like to take this opportunity to voice my opposition to the proposed development at the Fort Missoula Hospital. As the lead author of the recent expansion to the Fort Missoula National Register of Historic Places Nomination I will state unequivocally that this proposal will have an irreversible and lasting adverse impact to the historic qualities and values that make Fort Missoula eligible for the National Register. There are four historic resources that are part of this proposed development, the Post Hospital, the CCC Nurses Quarters, the CCC Garage and the Fort Missoula Historic Landscape. The Post Hospital is one of the grand buildings that represents the Fort Reconstruction Period of 1910 – 1912; it is a contributing structure to the historic district and in my professional opinion in the absence of a historic district it would be individually eligible for listing on the National Register. The proposed restoration and adaptive reuse of the Post Hospital is an idea that is long overdue and it is a vision that the Missoula community should support and appreciate. The restoration will be an expensive undertaking yet it is sorely needed. We should try to think outside of the box to find ways to help make this vision a reality. The CCC Nurses Quarters is a contributing structure to the Fort Historic District and it is reflective of the Civilian Conservation Corps building style that is scattered across our nation. Simple yet sturdy and functional in design, this building constructed by the CCC housed the nurses working at the Post Hospital. Like the Hospital, the restoration and adaptive reuse of this building is sorely needed and will be an expensive undertaking. I would caution that the preservation and restoration of both of these historic gems should follow the Secretary of the Interior’s Standards and Guidelines, I have not seen anything in any of the materials provided by the developers that the preservation efforts will utilize the highest preservation standards. The CCC Garage, located behind the CCC Nurses Quarters, has been suffering from benign neglect for decades and is in dire need of help. This building is also reflective of the architectural styles employed by the CCC at Fort Missoula as well across our nation. The garages behind Officer’s Row were also constructed by the CCC and they should serve as a blueprint for the restoration and preservation for this building. The plans for this building have changed and its future is not certain. Early plans called for deconstruction and removal; current plans envision moving the building. Either scenario would result in the building losing its National Register status. Fort Missoula also possesses a stunning and very visual historic landscape; the historic landscape is a contributing resource to the National Register Historic District. There are two historic eras’ from Fort Missoula’s lengthy and colorful past that are reflected in the landscape, the City Beautiful Movement and the Civilian Conservation Corps. During the Fort Reconstruction Period, the City Beautiful Movement swept the nation, the basic idea was that civic pride and appreciation of our public spaces would be enhanced by the landscape. There are elements of the City Beautiful Movement landscape that are still visible and scattered across the Fort. This includes buildings set back from streets, the curved streets, the presence of broad curved sidewalks meant to encourage a walkable environment, decorative lamp posts, wrought iron fences and the liberal use of a variety of plants to soften and humanize the appearance of a military installation. The proposed residential and commercial development would have a lasting and irreversible negative impact to the Fort Missoula Historic Landscape. I would also caution against the developer’s ideas for incorporating elements of the CCC style architecture in their residential and commercial plans. I am not opposed to new development at Fort Missoula, but I adamantly believe the development must be respectful and compatible with the historic values at Fort Missoula. There are two prime examples of modern development at Fort Missoula that reach these goals. The modern Bureau of Land Management offices are an example of compatible new construction in a historic district. The architects successfully created a modern government office building that blend into the Fort Missoula Historic District. The architects set the building back from the street scene, they employed berms and vegetation to break up the views of the building. They designed a short squat structure that utilized the distinctive red clay tiles and plain white adobe walls, architectural elements of the Spanish Mission style present in the tall stately buildings that gracefully line Officer’s Row. The Fort Missoula Regional Park is also an example of new development that is respectful of the Fort’s history. Missoula Parks and Recreation engaged in lengthy and successful conversations with the Fort stakeholders about the historic values of Fort Missoula. The resulting park is reflective of and honors the presence of the Civilian Conservation Corps and it is new development at the Fort that the Missoula community should consider with great pride. Any new development at Fort Missoula needs to