CNMI grades Air Force historic findings a ‘non-concurrence’


The Pacific Air Forces, a major command of the U.S. Air Force, has incorrectly gauged the potential effects to historical properties from a divert airfield on Saipan, according a letter sent from the Commonwealth government to the Air Force on Monday.

The CNMI—through the Historic Preservation Office—has written a letter of “non-concurrence” to the Air Force’s August findings of effect on historical sites. The letter details ways the Saipan Historical Landmark district would be compromised by the construction and operational activities of the proposed divert project on Saipan.

The letter comes two months after the Air Force proposed their findings of effects on these historical sites. In their August findings, the Air Force finds that the proposed action would have no direct adverse effect on contributing elements to the Aslito/Isley Field, of the Saipan Landing Beaches [a national historical landmark], Aslito/Isley Field, Marpi Point National Historic Landmark [NHL] or other historic properties on Saipan.

In their letter, HPO takes issue with PACAF’s method of analysis, which sticks to labeling and identifying effects as “direct or indirect.” According to the HPO letter, that is not the issue at hand, as federal historic preservation law requires federal agencies like the military to “resolves the potential adverse effects of their program.”

“On an island the size of 44 square miles, the proposed construction and operation activities will cause significant adverse affects to recognized historical properties,” writes HPO. “The construction and operational activities at the seaport and airport and the fuel transfer transportation route to and from the airport are all directly situated in the ‘heart’ of Saipan’s commercial and tourism districts.

“The incredibly small scale size of the island of Saipan is in the NMI opinion a controlling factor and should not be discounted or disregarded when evaluating potential adverse effects to a NHLD,” HPO writes.

Parking apron

HPO details the effects of a parking apron on two historical bunkers from World War II situated along the taxiway of the Saipan airport in an open field of grass with security fence off in the distance. HPO says these two bunkers are situated in highly visible and a prominent location at the Saipan landmark. Passengers departing or arriving on aircraft at the airport pass directly by these bunkers either on the way to and from the arrival/departure gates, HPO said.

HPO says the construction and use of a parking apron would be a “direct effect” on these two properties. “PACAF’s plan to build an apron near and/or around the bunkers (or, moving the apron a small number of feet) and to refuel jets parking on the apron when the field is in use will have direct effects… [Building] will affect the integrity and physical interpretation” of the landmark, HPO said.

Fuel storage and delivery system

HPO also objects to the construction of a fuel storage area and hydrant system that they say will “more than double the amount” of property currently used at the landmark to store fuel.

The proposed pipeline will be situated or pass within a small number of “feet” of two additional bunkers and only yards away from on the NHLD’s most outstanding historical Japanese military buildings, HPO wrote.

HPO says the fuel storage will close-off and fence-in a large amount of “open-space” at the landmark, as the area where it is proposed now is a completely unrestricted area and an common site for people on weekends and during holidays to picnic, exercise or run through.

“Fencing and closing-in open space within close proximity to historical properties would be obviously change the open and natural surroundings of these properties within the NHLD. Building a fence around the fuel storage and delivery system components will remove from the public the right of entry onto that property,” HPO said.

“Using this property as a restricted access area will result in a reduction in the size of the NHLD open and available to the public and affect the overall feel of the NHLD. Therefore, and contrary to PACAF’s assertion otherwise—the Divert undertakings at the Saipan NHLD would lead to additional access restriction and the fuel storage and delivery system will directly affect the NHLD.”

B-29 hardstand, old taxiway

HPO notes that the divert project’s parking apron, fuel storage facility, and maintenance building would all be built on B-29 hardstands or the landmark’s taxiway both inside and outside the airports security fence within the NHLD. HPO says this construction “right on top” of these features is further evidence of a direct adverse effect that would “conceal or shroud portions of historic properties in the NHLD.”

“While PACAF maintains that the hardstands are deteriorated and not recognizable, they nonetheless still form the basic network and fabric that ties the landscape setting together under the theme of the NHLD…They are significant historical components within the boundary of the Saipan’s NHLD devoted to the bygone airfield activities which will be directly impacted by the proposed project,” HPO said.

Titian option

HPO withheld comment on the findings on the “Tinian option” of the divert project, as they say an ongoing request between federal agencies to provide a National Park Service report on the impact of Marine Corps Forces Pacific plans to training in Tinian will discover that the two live-fire and divert plans are “potentially linked” and NPS would therefore consider the two projects in its report. That report is a Sec. 213 report under the National Historic Preservation Act.

Dennis B. Chan | Reporter
Dennis Chan covers education, environment, utilities, and air and seaport issues in the CNMI. He graduated with a degree in English Literature from the University of Guam. Contact him at

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