[Evaluation Report on Selected Management Activities at Manassas National Battlefield Park, National Park Service]
[From the U.S. Government Printing Office, www.gpo.gov]

Report No. 98-I-686

Title: Evaluation Report on Selected Management Activities at Manassas
       National Battlefield Park, National Park Service

Date:  September 21, 1998




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U.S. Department of the Interior
Office of Inspector General







EVALUATION REPORT


SELECTED MANAGEMENT ACTIVITIES AT MANASSAS
NATIONAL BATTLEFIELD PARK,
NATIONAL PARK SERVICE


REPORT NO. 98-I-686
SEPTEMBER 1998







MEMORANDUM


             TO:  The Secretary

           FROM:  Richard N. Reback
                  Acting Inspector General

SUBJECT SUMMARY:  Final Evaluation Report for Your Information
                  -  "Selected Management Activities at Manassas
                  National Battlefield Park, National Park
                  Service" (No. 98-I-686)


Attached for your information is a copy of the subject final
evaluation report.  The objective of the evaluation  was  to
determine whether officials at Manassas National Battlefield
Park  (1)   took   any  actions  to  improve  safety  at the
intersection  of  Routes  U.S.  29  and VA 234, (2) properly
planned   to  include  land  surrounding  the  Park  in  the
National Register of Historic  Places, and (3) executed land
use  practices  that  were  in  accordance  with  applicable
requirements.   The  evaluation was  conducted  based  on  a
February 25, 1998, letter  from  a Congressman who requested
an "evaluation of the park's resource  management  and  land
use    practices,    specifically   with   an   eye   toward
administrative abuses,  inconsistencies,  and  public safety
deficiencies."

We  noted  that  Park  officials and Virginia Department  of
Transportation  (Virginia   DOT)   officials   independently
determined that the intersection of Routes U.S.  29  and  VA
234  was  a "high accident location."  However, the Park and
Virginia DOT had made little progress in working together to
improve safety  at   the  intersection.  Specifically,  Park
officials did not approve a Virginia DOT proposal to improve
safety by constructing turning  lanes  at  the  intersection
but,  as  an alternative, proposed a modification to  change
the sequencing  of   the traffic signal at the intersection.
However, Virginia DOT officials said that they believed that
only changing the sequencing  of  the  traffic  signal would
increase  the risk of accidents at the intersection.    Park
officials said  that  they did not approve the proposal made
by  Virginia DOT officials   to  add  turning  lanes  at the
intersection  because  they  believed that this action would
conflict with the Park's legal  obligation  and  mission  to
preserve  and  protect  the historical scene of the National
Battlefield.  More importantly, we noted that Park officials
had  not  completed  a transportation  study  regarding  the
relocation of Routes U.S.  29  and  VA  234,  as required by
Public  Law  100-647, Manassas  National  Battlefield   Park
Amendments,  enacted   on   November 10, 1988.    We believe
that the inability of the Park  Service  and Virginia DOT to
agree  on  a  plan  of  action   contributed to  a  lack  of
significant   safety   improvements  being   made   at   the
intersection and prevented  viable  alternatives  from being
identified   to   enable   the  two  routes  that  form  the
intersection to be closed.

Further, we found that although  required  by the provisions
of its contract, a National Park  Service contractor did not
send a February 1998 letter to  all  landowners who could be
affected  by  a  study to identify property surrounding  the
Park for  nomination  to  the  National Register of Historic
Places.  The contractor stated that  the  lack  of  complete
notification was caused by an incomplete and inaccurate list
of  landowners  it  obtained  from  the  Park Service.  Some
landowners  who  were  not  notified  timely contacted  Park
Service   and   Government-elected  officials   to   express
concerns that their  property,  if  listed  on  the National
Register, would lose value, would be subjected to  land  use
limitations,  and  would  compromise Virginia DOT's plans to
construct a Route VA 234 bypass.

We also found, for 128 land  disturbances  recorded  between
1980  and  1997  by  Park officials, that Park officials had
complied  with the Code  of Federal Regulations (36 CFR 800)
as it pertains to the protection  of  historic property.  We
did not find any administrative abuses or inconsistencies.

We made five recommendations to the Park  Service to address
the deficiencies identified.  Based on the response from the
Park Service, we requested additional information for two of
the  recommendations  and  requested that the  Park  Service
reconsider   its   response   to   the    three    remaining
recommendations, which are unresolved.

If  you  have  any  questions concerning this matter, please
contact me at (202)   208-5745   or Mr. Robert J.  Williams,
Assistant Inspector General for Audits, at (202) 208-4252.


Attachment






Memorandum                                     I-IN-NPS-007-98-R


     To:  Assistant Secretary for Fish and Wildlife and Parks

   From:  Robert J. Williams
          Assistant Inspector General for Audits

Subject:  Evaluation Report on Selected Management
          Activities at Manassas National Battlefield Park,
          National Park Service (No. 98-I-686)


This  report  presents  the results of our evaluation of selected
management activities at Manassas National Battlefield Park.  The
evaluation was conducted  based  on  a  February 25, 1998, letter
from  a Congressman who requested an "evaluation  of  the  park's
resource  management and land use practices, specifically with an
eye toward  administrative  abuses,  inconsistencies,  and public
safety deficiencies."

Consistent with the request, the objective of our evaluation  was
to  determine  whether  Park officials  (1)  took  any actions to
improve safety at the intersection  of Routes U.S. 29 and VA 234,
(2) properly planned  to include land surrounding the Park in the
National Register of Historic Places,  and  (3) executed land use
practices that were in accordance with applicable requirements.

Manassas  National  Battlefield  Park  officials   and   Virginia
Department    of    Transportation   (Virginia   DOT)   officials
independently determined  that the intersection of Routes U.S. 29
and VA 234 was a "high accident location."  However, the Park and
Virginia DOT had made little  progress  in  working  together  to
improve   safety   at   the  intersection.   Specifically,   Park
officials did not approve  a  Virginia  DOT  proposal  to improve
safety by constructing turning lanes at the intersection  but, as
an  alternative, proposed a modification to change the sequencing
of  the  traffic  signal  at the intersection.  However, Virginia
DOT officials said that they  believed  that  only  changing  the
sequencing  of  the  traffic  signal  would  increase the risk of
accidents at the intersection.   Park officials  said  that  they
did not approve the proposal made by  Virginia DOT officials   to
add  turning lanes at the intersection because they believed that
this action  would  conflict with the Park's legal obligation and
mission to preserve and  protect  the  historical  scene  of  the
National  Battlefield.   More  importantly,  we  noted  that Park
officials had not completed a transportation study regarding  the
relocation  of  Routes  U.S. 29 and VA 234, as required by Public
Law 100-647, Manassas  National   Battlefield   Park  Amendments,
enacted  on  November 10, 1988.    We believe that  the inability
of the Park Service and Virginia DOT to agree on a plan of action
contributed  to  a lack of significant safety improvements  being
made at the intersection  and  prevented viable alternatives from
being  identified  to  enable  the  two   routes  that  form  the
intersection to be closed.

Finally, we found that although required by the provisions of its
contract, a Park  Service contractor did not send a February 1998
letter to  all  landowners who could be affected  by  a  study to
identify property surrounding Manassas National Battlefield  Park
for  nomination to the National Register of Historic Places.  The
contractor  stated  that  the  lack  of complete notification was
caused  by an incomplete and inaccurate  list  of  landowners  it
obtained  from  the  Park  Service.  Some landowners who were not
notified  timely contacted Park  Service  and  Government-elected
officials to  express  concerns that their property, if listed on
the National Register,  would  lose  value, would be subjected to
land use limitations, and would compromise  Virginia  DOT's plans
to construct a Route VA 234 bypass.

Regarding the third part of our objective, land use practices, we
conducted  a  limited  review  of  128 land disturbances recorded
between 1980 and 1997 by Park officials  and  determined  that to
the extent of our review, these officials complied  with the Code
of  Federal  Regulations  (36  CFR  800)  as  it  pertains to the
protection of historic property.  Based on our limited review, we
did not find any administrative abuses or inconsistencies.

We made five recommendations to the Park Service to  resolve  the
findings.    Specifically,   we  recommended  that  Park  Service
officials (1) seek funding to  conduct  the  study  required   by
Public  Law 100-647 to  identify ways to close Routes U.S. 29 and
VA 234, (2)  work  with  Virginia  DOT  officials  to  identify a
mutually   acceptable    approach   to   improve  safety  at  the
intersection, (3) inform Park visitors that the intersection is a
"high accident location" and that they should  be  cautious  when
driving  and/or walking in and around the intersection, (4)  work
with the Commonwealth  of  Virginia  or independently  notify all
landowners who could be adversely impacted  by  the  Park Service
study to identify land surrounding the Park for nomination to the
National  Register  of  Historic  Places  and inform them of  the
potential effects of their property being listed on the Register,
and (5) consider  private landowners' concerns in determining the
land to be included in a nomination to be listed on the Register.

In an August 19, 1998, response (Appendix 4)  to the draft report
from  the  Director,  National  Park  Service,  the Park  Service
concurred with one recommendation, indicated concurrence with one
recommendation,    and   indicated   nonconcurrence  with   three
recommendations.  Based on the response, we are requesting a plan
to implement Recommendations A.1 and A.2,  including target dates
for completion and titles of  responsible officials,  and  we are
requesting  that  the  Park  Service  reconsider its responses to
Recommendations  A.3,  B.1, and B.2, which  are  unresolved  (see
Appendix 6).

The legislation, as amended,  creating  the  Office  of Inspector
General  requires  semiannual  reporting to the Congress  on  all
audit   reports  issued,  actions  taken   to   implement   audit
recommendations,   and   identification   of   each   significant
recommendation on which corrective action has not been taken.

We  appreciate  the assistance of National Park Service personnel
in the conduct of our evaluation.


                                      CONTENTS

                                                                   Page

               INTRODUCTION......................................
               .................. 1

                         BACKGROUND..............................
                         .................. 1

                         OBJECTIVE AND
                         SCOPE...................................
                         .... 2

                         PRIOR AUDIT
                         COVERAGE................................
                         ...... 3

               FINDINGS AND
               RECOMMENDATIONS...................................
               ..... 4

                        A.  VISITOR SAFETY AND
                        PROTECTION.......................... 4

                        B.  NATIONAL REGISTER
                        NOMINATION.......................... 11

               APPENDICES

1.  ILLUSTRATION OF THE INTERSECTION OF ROUTES U.S. 29 AND VA
234................. 18

2.  ILLUSTRATION OF HIGHWAYS WITHIN MANASSAS NATIONAL BATTLEFIELD
PARK............ 19

3.  LAND USE PRACTICES AT MANASSAS NATIONAL BATTLEFIELD PARK,
1980 THROUGH 1997... 20

4.  NATIONAL PARK SERVICE
RESPONSE................................................ 25

5.  NATIONAL PARK SERVICE COMMENTS AND OFFICE OF INSPECTOR
GENERAL REPLIES........ 34

6.  STATUS OF EVALUATION REPORT
RECOMMENDATIONS................................... 51


INTRODUCTION

BACKGROUND

The  Organic  Act  of  August  25,  1916,  created  the
Department of the Interior National Park Service "to be
responsible  for  protecting  the  national  parks  and
monuments in existence at that time and those yet to be
established."   Consistent  with  the  Act,  the stated
mission of the Park Service is "to promote and regulate
the use of national parks, to conserve the scenery, the
natural and historic objects, and the wildlife,  and to
provide  for  the enjoyment of the same in such manners
and by such means as will leave them unimpaired for the
enjoyment of  future generations."

The United States  Code (23 U.S.C. 138) states that the
"Secretary [of Transportation], in cooperation with the
Secretary of the Interior  and  appropriate  state  and
local officials, is authorized to conduct studies as to
the  most  feasible Federal aid routes for the movement
of motor vehicular  traffic  through or around national
parks so as to best serve the  needs  of  the traveling
public  while  preserving the natural beauty  of  these
areas."  The Code further states:

It is hereby  declared  to  be  the  national
policy that special effort should be made  to
preserve    the   natural   beauty   of   the
countryside and  public  park  and recreation
lands,  wildlife  and waterfowl refuges,  and
historic    sites.     The    Secretary    of
Transportation  shall cooperate  and  consult
with the Secretaries of the Interior, Housing
and Urban Development,  and  Agriculture, and
with the States in developing  transportation
plans and programs that include  measures  to
maintain or enhance the natural beauty of the
lands traversed.  After the effective date of
the  Federal-Aid  Highway  Act  of  1968, the
Secretary   [of   Transportation]  shall  not
approve any program  or  project  . . . which
requires  the use of any publicly owned  land
from  a  public  park,  recreation  area,  or
wildlife and  waterfowl  refuge  of national,
State, or local significance as determined by
the Federal, State, or local officials having
jurisdiction  thereof,  or any land  from  an
historic site of national,  State,  or  local
significance   as   so   determined  by  such
officials unless (1) there is no feasible and
prudent alternative to the  use of such land,
and  (2) such program includes  all  possible
planning  to  minimize  harm  to  such  park,
recreational  area,  wildlife  and  waterfowl
refuge, or historic site resulting from  such
use.

In  addition,  according to its mission statement,  the
Park Service "encourages  people  to come to the parks,
and   to   pursue   inspirational,   educational,   and
recreational  activities  to  fulfill  its  mandate  to
provide for public enjoyment of the areas  it manages."
In  that  regard, the Park Service is required  by  its
management    policies   to   provide   visitors   with
"appropriate information  to  encourage safe and lawful
use  of  the  parks and to minimize  any  accidents  or
adverse impacts on park resources."  The Park Service's
"Loss Control Management  Guidelines" includes the Park
Service's policy and program requirements for achieving
a safe and healthful environment.   Chapter  22  of the
"Guidelines"    specifies    the    "minimum    program
requirements  for  protecting  the visiting public from
recognized  hazards  related  to  Department   of   the
Interior  and  Park  Service facilities or operations."
The  "Guidelines"  generally   states   that  the  Park
Service's regions and parks "should establish  a public
safety program that minimizes the potential for injury,
illness,  death  and/or  property  damage to the public
while  they  are  visiting  Park  Service  facilities."
Section A of the "Guidelines" states that "every effort
should be made to identify the hazards in the park/area
that  have  caused  or  have  the potential  to  cause,
injury, illness, death or property damage to park visi-
tors."  In addition, Section G  states  that "all areas
will provide any special materials, signs  and programs
to alert the public of potential dangers and  brochures
specific  to  the  area  should contain safety messages
that direct attention to special hazards or attractions
that could be potentially hazardous to the visitor."

OBJECTIVE AND SCOPE

The  objective  of  our  evaluation  was  to  determine
whether Manassas National  Battlefield  Park  officials
(1)   took   any  actions  to  improve  safety  at  the
intersection of Routes U.S. 29 and VA 234, (2) properly
planned  to include  land  surrounding  the Park in the
National Register of Historic Places, and  (3) executed
land   use  practices  that  were  in  accordance  with
applicable requirements.

Our evaluation of selected management activities at the
Park was conducted based on a February 25, 1998, letter
from a Congressman  who  requested  that  we perform an
"evaluation of the park's resource management  and land
use   practices,   specifically   with  an  eye  toward
administrative  abuses,  inconsistencies,   and  public
safety deficiencies."

The  evaluation  was conducted from March through  July
1998  at  Manassas  National   Battlefield   Park,   in
Manassas,  Virginia, and at the National Park Service's
National Capital  Region, in Washington, D.C.  As  part
of  the  evaluation, we  conducted interviews with  (1)
Park Service officials to obtain information concerning
current Park functions and activities, (2) Virginia DOT
officials to obtain  information  concerning the safety
of the intersection of Routes U.S.  29  and  VA 234 and
the  proposed  Route VA 234 bypass, (3) Virginia  State
Historical  Preservation  Office  officials  to  obtain
information  concerning  their  role  in  the  National
Register of Historic Places  nomination process and the
Park Service's  compliance with historical preservation
regulations, and  (4)  the Park Service's contractor to
obtain information concerning a historic resource study
to  identify  land appropriate  for  inclusion  on  the
National  Register.    We   also   reviewed   documents
pertaining to land use and the historic resource  study
to   test   compliance   with   historic   preservation
regulations  and documents pertaining to safety  issues
to  identify  Park   officials'   responsibilities  and
activities  related  to  safety  at  the  intersection.
Furthermore,  we   reviewed  highway collision  records
maintained  by Virginia DOT to  determine  the  current
conditions of the intersection.

The evaluation  was  conducted  in  accordance with the
"Quality  Standards  for Inspections,"  issued  by  the
President's Council on  Integrity  and Efficiency, and,
accordingly,   included   such  tests  and   evaluation
procedures that were considered necessary to accomplish
the  objective.   We  also  reviewed  the  Departmental
Report on Accountability for  fiscal  year  1997, which
includes information required by the Federal  Managers'
Financial Integrity Act of 1982, and the Park Service's
annual  assurance statement on management controls  for
fiscal  year  1997  and  determined  that  no  material
weaknesses  were  included  in  these  documents  which
directly  related  to  the  objective  and scope of our
evaluation.   As  part of our review, we evaluated  the
system of internal  controls  to  the  extent that they
related  to the objective and scope of the  evaluation.
The  internal   control   weaknesses   identified   are
discussed  in  the Findings and Recommendations section
of this report.   Our  recommendations, if implemented,
should improve internal controls in these areas.

PRIOR AUDIT COVERAGE

Neither the Office of Inspector General nor the General
Accounting Office has issued  any  reports  during  the
past  5  years that addressed the areas included in our
evaluation.

FINDINGS AND RECOMMENDATIONS

A.  VISITOR SAFETY AND PROTECTION

Manassas  National   Battlefield   Park  officials  and
Virginia  Department of Transportation  (Virginia  DOT)
officials    independently    determined    that    the
intersection of  Routes  U.S. 29 and VA 234 was a "high
accident location."  However,  Park  and  Virginia  DOT
officials  had made little progress in working together
to improve safety  at  the intersection.  Specifically,
Park  officials  did  not    approve  a   Virginia  DOT
proposal   to improve safety by  constructing   turning
lanes  at the  intersection  but,  as  an  alternative,
proposed a modification to change the sequencing of the
traffic  signal  at  the  intersection.  Park officials
stated  that  they  had  not  approved  Virginia  DOT's
proposal to construct turning lanes at the intersection
because  they   believed that substantial  improvements
would conflict with the National Park Service's mission
of preserving and  protecting  the  historical scene of
the  National Battlefield.  More importantly,  although
Park Service  officials  provided  us a list of actions
they said had been initiated around the intersection to
improve safety, the Park Service had  not completed the
transportation  study  to  identify ways to  close  the
intersection, an action which  was  required  by Public
Law   100-647,   Manassas   National  Battlefield  Park
Amendments, enacted on November 10, 1988.  Park Service
officials  stated  that  the study,  which  was  to  be
completed  by November 1989,  had  not  been  conducted
because  of  lack  of funds.  However, the Park Service
did not provide any  documentation  to  show  that  the
funds were requested in subsequent budgets.  We believe
that the inability of the Park Service and Virginia DOT
to  agree  on a plan of action contributed to a lack of
significant  safety  improvements  being  made   at the
intersection  and  prevented  viable  alternatives from
being identified to enable the two routes that form the
intersection to be closed.  Furthermore,  we found that
Park  Service officials had not informed Park  visitors
of  the  potential  hazards  of  the  intersection,  as
generally  required  by the Park Service's  mission and
management guidelines,  stating that they believed that
the  Commonwealth of Virginia  and  not  the  Park  was
responsible for the safety at the intersection and that
the Park  Service  was  not  responsible  for providing
warnings to Park visitors of the  potential  hazards at
the  intersection.  According to its mission statement,
the National  Park Service "will seek to provide a safe
and healthful environment  for  visitors  and employees
and work cooperatively with other Federal,  state,  and
local agencies, organizations, and individuals to carry
out this responsibility."

Intersection of Routes U.S. 29 and VA 234

The  intersection  of Routes U.S. 29 and VA 234 (map at
Appendix 1) is located  near the geographical center of
Manassas National Battlefield Park ( map at Appendix 2)
and can be
seen from Henry Hill[1] and  the Visitors Center within
the  Park.  Route U.S. 29 is a  two-lane  highway  that
runs northeast to southwest, and Route VA 234 is a two-
lane highway  that  runs  north  to  south.  There is a
three-light  traffic  signal  at  the  intersection  to
control  traffic  flow.  Based  on  information   in  a
transportation study performed by a contractor for  the
Park  Service  and according to Virginia DOT officials,
the intersection  was a "high accident location."  Park
visitors responding  to  a survey conducted by the Park
Service indicated that Routes U.S. 29 and VA 234 in and
around the intersection were dangerous.

       Intersection Safety.   On  May 18, 1995,
the  Park  Service awarded a contract  totaling
$112,500  for   a   transportation  study  that
"examined    the   operational    and    safety
characteristics  of  the  traffic  and  parking
conditions" within the Park.  In June 1996, the
Park  Service  received  the  report  "Manassas
National   Battlefield   Park,   Transportation
Study" from the contractor.  The report covered
the period of calendar years 1991 through 1994,
and  its  executive  summary   stated  that  "a
traffic  safety  analysis indicates  that  most
accidents within the  Park occur on U.S. 29 and
VA  234."  The summary also  stated  that  "the
greatest  operational  problem [in the Park] is
the signalized intersection  of  U.S. 29 and VA
234.   The  signal  is  currently operating  at
capacity . . . .  Erratic  vehicular  maneuvers
associated with the traffic congestion  at this
intersection are a safety concern."

Based  on  data presented in the study, the  contractor
also  concluded  that  the  intersection  was  a  "high
accident   location."    According   to  a  contracting
official who worked on the study, the  accident  rating
was  based  on  industry  guidelines  published  by the
Institute  of  Transportation  Engineers,  which  is an
international  organization.  We reviewed the collision
statistics of the  intersection  included  in the study
for  calendar  years  1991 through 1994 (237 accidents)
and   updated  the  statistics   based   on   collision
statistics  maintained  by  Virginia  DOT  for calendar
years 1995 through 1997 (51 accidents).  The  collision
statistics   showed  that  288  traffic  accidents  had
occurred at or  approaching the intersection for the 7-
year  period  (1991   through   1997).   The  collision
statistics  showed  that the 288 accidents  caused  176
injuries  and 3 fatalities  to  vehicle  occupants  and
injury to one  pedestrian and 134 instances of property
damage.

The 1996 transportation  study concluded that 63 of the
accidents occurred directly in the intersection of U.S.
29 and VA 234, resulting in  an  accident  rate for the
intersection  of  2.38  accidents  per million vehicles
entering the intersection.  The study  stated,  "If  an
intersection  has  an  accident  rate  that exceeds one
accident   per   million  vehicles  entering,   it   is
considered to be a  high  accident  location,  whereas,
rates  exceeding  three  accidents per million vehicles
entering  are considered very  hazardous."   The  study
further  stated   that   "the  accident  rate  for  the
intersection is believed to  be  much greater than 2.38
accidents    per   million   vehicles   entering    the
intersection because  it was very likely that accidents
related to the congestion  at the intersection extended
much farther back from the intersection  than  the two-
tenths   of   a   mile   used   in  the  accident  rate
calculations."

In  addition, Virginia DOT officials  stated  that  the
intersection was a "high accident location" based on an
accident  rate  of 1.59 accidents per million  vehicles
entering   the intersection  for  calendar  years  1994
through 1997.   This   accident  rate  was  2.27  times
the  Virginia  DOT  "high  accident   rating"   of   .7
collisions   per  million  vehicles.   A  Virginia  DOT
official stated  that the intersection's collision rate
was  in the 85th percentile  Commonwealthwide  and  was
determined  to  be  a  "high  accident  location" under
Virginia DOT standards.

We also reviewed comments made by Park visitors as part
of  a  Park Service survey conducted in the  summer  of
1995.  A consensus was compiled by Park officials using
the responses  to  the survey questionnaire for several
Park  activity  categories.    The    "Facilities   and
Maintenance"   and  "Policies"categories  of  the  Park
visitor  study  indicated  that  visitors  as  a  whole
expressed concerns  primarily  related to improving the
traffic flow (mentioned 17 times)  and  reducing  speed
limits (mentioned 6 times) in the Park  In addition, we
reviewed  the  responses to the specific question "what
did  you  like  least  about  your  visit  to  Manassas
National Battlefield  Park?"  and compiled the comments
that were specifically related  to  the intersection of
Routes U.S. 29 and VA 234, which were not summarized by
the Park as part of a Park activity category.  Although
there were various types of complaints  received  about
safety,  we  noted  that  10  visitors,  representing 2
percent  of  those  surveyed, expressed concerns  about
excessive  traffic  speed   and   noise  and  dangerous
conditions  in  and  around  the  intersection.     For
example, visitors said the following:

"Dodging  traffic  on  the  self-guided  auto  tour.
Accidents have to happen.  Very dangerous there."

-"On  your  auto tour you need to post more signs along
the roadway to allow  enough  time to signal and turn safely
because Rt. 29 and Rt. 234 are heavily traveled."

       Safety  Requirements.   The  Park  Service's  mission
states that "the saving of human  life  will take precedence
over  all  other  management  actions.   The  National  Park
Service and its contractors will seek to provide  a safe and
healthful environment for visitors and employees.   The Park
Service  will  work cooperatively with other Federal, state,
and local agencies,  organizations, and individuals to carry
out this responsibility."   Also,  the  Park Service's "Loss
Control Management Guidelines" includes Park  Service policy
and program requirements for achieving a safe and  healthful
work   environment   and   "specifies  the  minimum  program
requirements  for  protecting   the   visiting  public  from
recognized hazards related to Department of the Interior and
Park Service facilities or operations."

The Park Service's 1996 transportation  study stated that in
1985, "Virginia DOT recommended improving  the safety at the
intersection  of  routes  U.S.  29  and  VA  234  by  adding
dedicated  left turn lanes on all approaches and right  turn
lanes on two  approaches,  thereby  increasing the number of
lanes  at  the  intersection  from 8 to 14."   Virginia  DOT
officials stated that "all road  widening  on U.S. 29 can be
accomplished with the existing Virginia DOT right-of-way and
the  widening  on  VA  234, north of the intersection  would
require about 8 feet of  additional right-of-way on the west
side of the road and additional  right-of-way at the corners
of the intersection for traffic signals."  However, Virginia
DOT needed Park Service approval to  construct turning lanes
on  Route  VA  234.  In a November 7, 1997,  letter  to  the
Congress, Park officials  stated that they would not grant a
permit for the proposed modifications to the intersection on
the grounds that "the intersection widening would destroy or
otherwise  compromise the historic  scene  of  the  National
Battlefield."   Park  Service  documents  stated  that  "the
intersection  was  a major rural crossroads before the Civil
War and both battles  of Manassas were fought at or near the
intersection.  Major General John Pope's headquarters during
[the] Second [battle of]  Manassas  were less than 100 yards
from the intersection, and dozens of  wounded  soldiers from
both  sides  in the battles were treated in Stone  House,[2]
which is at the intersection."

Also in the November  1997  letter, as an alternative to the
Virginia DOT approach,  Park  Service  officials stated that
they would issue a permit to allow only  an upgrading of the
traffic  signal  from a three-light signal to  a  five-light
signal  to  accomplish  sequencing  of  the  lights  at  the
intersection.   According  to  Park  officials,  the  signal
phasing  would  result  in the following: (1) during a green
light for the southbound approach on Route VA 234, the three
other approaches would experience  a  red  light; (2) during
the green light for the northbound approach, the three other
approaches would experience a red light; (3) phasing for the
eastbound approach would include a leading green  light with
a green turning arrow while the three other approaches would
experience a red light; and (4) the westbound approach would
require no change in that a green light would be experienced
for  westbound  and  eastbound approaches and the northbound
and southbound approaches  would  experience a red light.  A
Virginia  DOT official stated that "sequencing  the  traffic
signals in  this  manner  at Routes U.S. 29 and VA 234 would
cause  traffic to come to a  standstill  due  to  the  large
volume of  traffic that would be waiting during multiple red
signal phases."   According  to  a  Virginia  DOT  official,
driver   frustration   and   delays  are  common  causes  of
accidents.  To be fully compliant with its mission statement
and the "Guidelines," we believe that Park Service officials
should work with Virginia DOT officials to improve safety at
the intersection.

More  importantly,  we noted that  Park  officials  had  not
completed a transportation study regarding the relocation of
Routes U.S. 29 and VA  234,  as  required by Public Law 100-
647, Manassas National Battlefield  Park Amendments, enacted
on  November  10, 1988.  Section 10004  of  the  Public  Law
states that "the  Secretary  of the Interior shall cooperate
with   the   Commonwealth   of   Virginia,   the   political
subdivisions thereof, and other parties as designated by the
Commonwealth  or  its  political subdivisions  in  order  to
promote and achieve scenic preservation of views from within
the park through zoning  and such other means as the parties
determine feasible."  The  public  law  further requires the
Secretary  to work with the Commonwealth  of  Virginia,  the
Federal Highway Administration, and Prince William County to
conduct a study to identify ways to close Routes U.S. 29 and
VA  234  in  the  vicinity  of Manassas National Battlefield
Park.   As  stated,  the  study,   "with   extensive  public
involvement   in  its  preparation,"  was  to  "specifically
consider and develop plans for closing routes U.S. 29 and VA
234 that transect  the  Park  and include analysis of timing
and  method  of  such  closures  and  of  means  to  provide
alternative routes for traffic now  transecting  the  Park."
According to the Act, the study should have determined  when
and  how  to close Routes U.S. 29 and VA 234 by November 10,
1989.  Park officials stated that the required study had not
been  performed   because  they  were  awaiting  input  from
Virginia DOT and because  funds had not been appropriated to
conduct   the   study,  but  officials   did   not   provide
documentation to  support that they had requested the funds.
By  not conducting the  required  study,  the  Park  Service
caused   delays   in   identifying  acceptable  options  for
improving safety at the  intersection.  Further, the closing
of the intersection to traffic  would be compatible with the
Park's   mission   of   promoting   and   achieving   scenic
preservation of views from within the Park.

We also noted that Park officials had not warned visitors of
the  "high  accident location" (Routes U.S. 29  and  VA  234
intersection),  as  required  by its "Guidelines."   In that
regard,  responses by Park visitors to the 1995 Park Service
survey stated road safety concerns as follows:

    - "Crossing Sudley Road [Route  VA  234]  by foot if you
parked  by  the  Information  Bldg.   At  times Sudley  Road
becomes a major thrufare for vehicles.  And  then it becomes
a race for your life to get on the other side  of Sudley Rd.
so you can enjoy the rest of the park."

    - "The roadway from Sudley [Route VA 234 heading  south]
.   .   .  is  the  worst  public  park  road  I  have  ever
encountered."

While Park Service officials agreed that the intersection is
a "high accident  location,"  they had not taken any actions
to warn visitors of the potentially  hazardous intersection,
nor had they implemented three recommendations  included  in
the Park Service's June 1996 transportation study to install
pedestrian warning signs at various locations throughout the
Park,  which  were estimated to cost $1,250.  Park officials
stated  that they  had  not  warned  visitors  because  they
believed  that the Commonwealth of Virginia and not the Park
was responsible  for  the  safety  of  Park  visitors at the
intersection  because  the  state  was  the  owner  of   the
highways.    However,   regardless   of  ownership  and  the
Commonwealth of Virginia's responsibility,  we  believe that
the Park is  responsible for visitor safety consistent  with
its  mission  statement  and  external  guidelines and  Park
activities require the use of Routes U.S.  29  and  VA  234,
which  are  in  the  center  of  the Park.  For example, the
intersection is included on a driving  tour of the Park, and
visitors have to enter and exit roadside interpretive areas;
cross through the intersection or enter  and  exit the small
parking  lot  at Stone House, which is directly adjacent  to
the intersection;  and  cross  Route  VA 234 to get to Dogan
Ridge,[3] another major attraction at the Park.

The  February 25, 1998, letter from the  Congressman  stated
that Park  officials had "disturbed" land for other purposes
but that the Park Superintendent "will not yield land at the
intersection  for  public safety needs."  To respond to this
concern,  we  conducted   a   limited  review  of  128  land
disturbances by the Park that occurred  from  1980  to 1997,
and  we determined that to the extent of our limited review,
Park  officials  had  complied  with  the  Code  of  Federal
Regulations  (36  CFR  800)  related  to  the  protection of
historic  property  (see Appendix 3).  Based on our  limited
review, we did not identify  any  administrative  abuses  or
inconsistencies.

Recommendations

We  recommend  that  the  Director,  National  Park Service,
ensure that:

     1.  Funds needed for the study are requested  and  that
Park officials conduct the study required by Public Law 100-
647 to identify ways to close Routes U.S. 29 and VA 234.

     2.  The Park Superintendent works with the Commonwealth
of  Virginia's  Department  of Transportation to determine a
mutually  acceptable  approach  to  improve  safety  at  the
intersection of Routes U.S. 29 and VA 234.

     3.  Park officials  inform  visitors  at  various  Park
locations that the intersection at Routes U.S. 29 and VA 234
is  a  "high  accident location" in accordance with the Park
Service's  "Loss  Control  Management  Guidelines"  and  its
management policies  and  that  visitors  should be cautious
when driving and/or walking in and around the intersection.

National  Park  Service  Response  and  Office of  Inspector
General Reply

In the August 18, 1998, response (Appendix  4)  to the draft
report  from the Director, National Park Service,  the  Park
Service   concurred   with   Recommendation   1,   indicated
concurrence    with    Recommendation   2,   and   indicated
nonconcurrence  with  Recommendation   3.    Based   on  the
response,     additional    information    is   needed   for
Recommendations 1 and 2, and we are requesting that the Park
Service reconsider its response to Recommendation  3,  which
is  unresolved  (Appendix  6).   In  its  response, the Park
Service also provided additional comments.   Those  comments
and our replies are in Appendix 5.

Recommendation 1.  Concurrence stated.

National Park Service Response. The Park Service
agreed with the recommendation.

     Office  of  Inspector  General  Reply.   Based  on  the
response,  we  request  that the Park Service provide a plan
that outlines actions to  be  taken  to  complete the study,
including   a   target   date  and  title  of  the  official
responsible for implementing the recommendation.

Recommendation 2.  Concurrence indicated.

National Park Service Response. In its response, the
Park Service stated:

     The  park  superintendent  has  worked  with  VDOT
     [Virginia Department of Transportation] to attempt
     to  find mutually acceptable solutions, which  are
     legally   permissible   under   Federal  laws  and
     regulations,  to  address  safety  issues  at  the
     intersection  of  Routes  29 and 234, and  he  and
     other NPS [National Park Service]  officials  will
     continue to do so.

     Office  of  Inspector  General  Reply.   Based  on  the
response,  we  request  that the Park Service provide a plan
that outlines the actions  to  be  taken  to  find  mutually
acceptable solutions, including a target date and the  title
of   the   official   responsible   for   implementing   the
recommendation.

Recommendation 3.  Nonconcurrence indicated.

     National  Park  Service  Response.    The  Park Service
stated  that "it does not have the legal authority  to  post
signs on  state  roads.   The  VDOT  [Virginia Department of
Transportation]  does  have  that  authority.    Thus,  this
recommendation should have been made to VDOT."

     Office  of  Inspector General Reply.  Contrary  to  the
Park Service's response,  we did not recommend that signs be
posted on state roads.  We  recommended that "Park officials
inform visitors that the intersection  at Routes U.S. 29 and
VA 234 is a `high accident location'. .  . and that visitors
should be cautious when driving and/or walking in and around
the intersection."  The posting of pedestrian  warning signs
was  a  recommendation  included in the Park Service's  1996
traffic study.  Our recommendation  was  intended to provide
Park Service officials maximum flexibility  in  deciding how
to   inform   visitors  of  the  potential  hazards  of  the
intersection, including requesting support from Virginia DOT
to get signs posted  on the roads if appropriate.  The  Park
Service is requested to  reconsider  its  response  to  this
recommendation.

**FOOTNOTES**

[1]:The  site  where Confederate soldiers made a final stand
against the Union Army during the Battle of Manassas.

2  Confederate  General  John  Pope  made  his  headquarters
directly behind Stone  House,  which  also served as a field
hospital during the first and second battles of Manassas.

3  The  Confederate  Army  under  the  leadership  of  General
Stonewall  Jackson was posted along an  unfinished  railroad
grade  (about   one-half  mile  west  of  Dogan  Ridge)  and
successfully held  its  position despite repeated attacks by
the Union Army, which had rear artillery positions along the
low ridges.
B.  NATIONAL REGISTER NOMINATION

We found that Manassas National  Battlefield  Park officials
were not required by law or regulation to notify  landowners
of the Park's plans to conduct a historic resource study and
prepare  a  nomination  to update the Park's listing on  the
National Register of Historic  Places.   However,  the  Park
Service's  contractor,  who  was required by  the contract's
statement of work to notify all of the private landowners in
the study area, notified only  56  of 185 private landowners
of the proposed study.  This action was contrary to the Park
Service's  mission  and to the verbal  advice  of   Virginia
State Historic  Preservation  Office  officials  to  provide
advance  notice  to landowners to obtain public support  for
National Register  nominations.  The 129 landowners were not
notified because the contractor obtained names and addresses
from  the  Park's  database   of   landowners,   which   was
incomplete  and  inaccurate.   Also, when the Park Service's
contractor became aware that the  database  was  inaccurate,
the  contractor  waited  to obtain an accurate listing  from
Park officials, which Park  officials  received  from Prince
William County on or about April 2, 1998.  However, the lack
of timely notification caused  private landowners to contact
their elected officials to express their concerns that their
property  listed on the National Register would lose  value,
would  be subjected  to  land  use  limitations,  and  would
compromise  Virginia DOT's plans to construct a Route VA 234
bypass.

           National Register of Historic Places

According to  the  Code  of Federal Regulations (36 CFR 60),
the National Historic Preservation  Act of 1966, as amended,
authorized the Secretary of the Interior

     .  . . to expand and maintain a National  Register
     of districts,  sites,  buildings,  structures, and
     objects    significant    in   American   history,
     architecture, archeology, engineering and culture.
     The  National Register of Historic  Places  is  an
     authoritative  guide to be used by Federal, State,
     and local governments, private groups and citizens
     in  order  to  identify   the   Nation's  cultural
     resources  and to indicate what properties  should
     be considered  for  protection from destruction or
     impairment.

The Act also stated that properties can be added to the
National Register through the following processes:

     Those  Acts of Congress and Executive orders which
     create  historic areas of the National Park System
     administered by the National  Park Service, all or
     portions  of  which  may  be  determined  to be of
     historic  significance  consistent with the intent
     of Congress;

     Properties  declared  by  the   Secretary  of  the
     Interior  to  be  of  national  significance   and
     designated as National Historic Landmarks;

     Nominations prepared under approved State Historic
     Preservation   Programs,  submitted  by  the State
     Historic Preservation Officer and  approved by the
     Park Service;

     Nominations  from  any  person or local government
     (only if such  property is located in a State with
     no approved State Historic   Preservation Program)
     approved by the Park Service; and

     Nominations  of  Federal  properties  prepared  by
     Federal  agencies  (referred   to   as  a  Federal
     nomination),   submitted  by the agency's  Federal
     Preservation Officer and approved by Park Service.

According to the Code of Federal  Regulations  (36  CFR 60),
which  implements  provisions  of the Act, "a nomination  to
propose  that  a district, site,   building,  structure,  or
object  be  listed   in  the  National  Register  begins  by
preparing the National  Park  Service's,  `National Register
Nomination  Form,'  with accompanying maps and  photographs,
which adequately document  the  property."  The Code further
states:

     The  nomination  form  is  a  legal  document  and
     reference  for   historical,  architectural,   and
     archeological data upon which the  protections for
     listed   and   eligible  properties  are  founded.
     Descriptions  and   statements   of   significance
     included  in  the nomination must be  prepared  in
     accordance with  standards  generally  accepted by
     academic historians, architectural  historians and
     archeologists.

     Notification to Private Landowners.   With  Public  Law
100-647,  the  Congress  added  about  600  acres of land in
Manassas,  Virginia, to Manassas National Battlefield  Park.
During  fiscal   year  1997,   Park  officials  initiated  a
nomination process  by  hiring  a  contractor  to  conduct a
historic  resource study and prepare the nomination form  to
include the  600  acres  of land and to determine whether to
include private land adjacent  to  the  Park on the National
Register  of  Historic Places.  During our  review  of  this
nomination process,  we  determined  that the Park Service's
contractor  attempted  to  notify landowners  who  might  be
affected  by the study but did  not  notify  all  landowners
because  the  contractor  used  the  Park's  incomplete  and
inaccurate  database  to  prepare  the notification letters.
This incomplete notification was inconsistent  with the Park
Service's  mission  and  statement of work for the  historic
resource study and the advice  of  Virginia  State  Historic
Preservation   Office  officials  to  notify  landowners  in
advance  of  nominating  their  property  for  the  National
Register of Historic  Places.  A more detailed discussion of
this issue is presented in the paragraphs that follow.

On September 26, 1997,  the  National Park Service awarded a
firm-fixed-price contract in the  amount  of  $22,000  to  a
research   and   consulting   firm   that   specializes   in
architectural  history and preservation studies to conduct a
historic resource study of the Park.  The contract stated:

     The  National   Register   nomination   form  will
     document   all   historic  properties  within  the
     authorized boundaries  of  the Park.  Adjacent and
     related properties may also  be  included  in  the
     revised   nomination   provided   the   respective
     landowners  give written consent for inclusion  of
     their  property   within   an   expanded  National
     Register district. [Emphasis added.]

On  November  18, 1997, Park officials sent  letters  to  77
private landowners  stating  that "the Park was conducting a
year-long historic resource study  of  the Manassas National
Battlefield Historic District."  The letters  further stated
that "several cultural resource surveys were conducted which
had identified additional historic resources in and adjacent
to  the  Park that appeared to justify an expansion  of  the
present  historic  district  and  that,  if  the  landowners
objected to  the  study,  they  were  to  contact  the  Park
Superintendent."   Several  private  landowners who had  not
been notified subsequently became aware  of  the  study  and
told  Park  officials that they had not been notified of the
Park's plans.   In  response, Park officials added the names
of six individuals to  the  initial mailing list and deleted
three names from the mailing list.

On December 3, 1997, the contractor  sent a second letter to
80 landowners that notified them of  the  study and enclosed
a map of the battlefield, which, according to Park officials
and the contractor, "was mistakenly left out  of  the  first
letter."   Although  several private landowners had not been
notified after the first  notification,   Park officials did
not  make  a concerted effort to correct their  database  of
landowners to ensure that all landowners who had land within
the study area were included in the second notification.  In
that regard,  Park  officials made changes to the list based
only  on  the  specific  complaints  they  received  without
determining whether the list needed to be updated before the
second mailing.

During our evaluation,  Park  officials  obtained a listing,
dated  April  2,  1998,  from  the  Prince  William   County
Geographic    Information    Technology    Division,   which
represented  the  private landowners surrounding  the  Park.
The  list  contained   the   names,  addresses,  and  parcel
identifications of 185 private  landowners.   We  noted that
only  56  of the 80 private landowners who had been notified
by the contractor were on the Prince William County listing.
We determined  that  the  24  remaining letters were sent in
error because of incorrect names  or addresses in the Park's
database. Thus, at least 129 private  landowners  (185 minus
56)  were  not  officially  notified of the Park's plans  to
consider  their  lands  in  a  nomination  to  the  National
Register of Historic Places.

Park officials stated that they  were not planning to notify
any more private landowners because  "they  did  not have to
notify private citizens that they were conducting a historic
resource  study and that the notification letters that  were
sent to some  of  the landowners were, indeed a courtesy, to
gain public support."   Also,  Park officials said that they
believed the Code of Federal Regulations  (36 CFR 60.10) did
not require notification of private landowners  by  the Park
Service when a district is jointly nominated by Federal  and
state agencies.  The Code states:

     State  Historic  Preservation Officers and Federal
     Preservation Officers  are encouraged to cooperate
     in   locating,   inventorying,   evaluating,   and
     nominating all properties  possessing  historical,
     architectural,  archeological, or cultural  value.
     Federal agencies  may  nominate properties where a
     portion  of  the property  is  not  under  Federal
     ownership or control.   When a portion of the area
     included in a Federal nomination is not located on
     land under the ownership or control of the Federal
     agency, but is an integral  part  of  the cultural
     resource, the completed nomination form  shall  be
     sent  to  the  State Historic Preservation Officer
     for  notification  to  property  owners,  to  give
     owners  of  private  property  an  opportunity  to
     concur  in or object to the nomination, to solicit
     written comments  and  for submission to the State
     Review Board.

The legal responsibility under  the  Code requires the state
rather  than  the  Federal  Government  to   notify  private
landowners  once it receives a Federal nomination  during  a
state and Federal  concurrent nomination of a historic place
to the National Register  of  Historic  Places.  However, as
stated   previously,   the  Park  Service's  contractor  was
required to notify landowners  of the study.  Also, the Park
Service's mission states that Park officials should "provide
opportunities for citizens to participate  in  the decisions
and actions of the Park Service." Furthermore, according  to
officials from Virginia's State Historic Preservation Office
and  National Park Service headquarters, the notification of
all private  landowners  should  be  considered  a  priority
during  a  nomination  to  the National Register of Historic
Places.  In that regard, State  Historic Preservation Office
officials told us that they met with Park personnel in March
1997  to  discuss  the  Park's  current   National  Register
nomination.   These  officials advised us that  during  this
meeting,  they discussed  "an  important  lesson"  they  had
learned from the nomination of Brandy Station Battlefield in
Virginia's  Culpeper  and  Fauquier Counties.  Specifically,
after that nomination process,  the  Congress  required  the
Keeper  of  the National Register to delist certain areas of
the nomination  because  the  landowners  did not want their
property involved.  As a result, Virginia officials  advised
Park  officials  that,  as  part  of  Virginia's  nominating
procedures,  they  involve  private  landowners  to gain  an
insight  as  to  whether there is public support before  and
during the process.   Virginia  officials  stated during the
meeting  that  Park officials should gain support  from  the
private landowners  by also notifying them of their plans to
conduct a historic resource  study to consider the expansion
of the historic district.

     Effects  of Incomplete Notification.   Because  private
landowners were  not  fully  notified,  they contacted their
elected  officials to present their beliefs  that   property
listed on  the National Register of Historic Places would be
subjected to  use  limitations  and that a plan developed by
Virginia DOT for the Route VA 234  bypass,  which  would  be
constructed west of the City of Manassas and the Park, would
be  compromised.   Based  on  our  review  of  eight letters
included   with  the  February  25,  1998,  letter  from   a
Congressman,  we  found that the private landowners believed
that the use limitations  would  cause their property values
to decrease.  Regarding property use  limitations,  the Code
of  Federal Regulations (36 CFR 60) states that "listing  of
private  property on the National Register does not prohibit
under Federal  law  or  regulation  any  actions  which  may
otherwise be taken by the property owner with respect to the
property."   Regarding  the  bypass,  the  Code  of  Federal
Regulations (23 CFR 771) regarding highways states that  any
Federal  highway  project  proposed  for a historic district
would be subjected to limiting guidelines.  The Code states:

     The Federal Highway Administration may not approve
     the use of land from a  significant publicly owned
     park  or any significant historic  site  unless  a
     determination  is made that:  there is no feasible
     and prudent alternative  to  the  use of land from
     the  historic  site;  and the action includes  all
     possible planning to minimize harm to the property
     resulting from such use.   Supporting  information
     must  demonstrate that there are unique   problems
     or  unusual   factors   involved  in  the  use  of
     alternatives that avoid these  properties  or that
     the  cost,  social,  economic,  and  environmental
     impacts,  or community disruption  resulting  from
     such  alternatives reach extraordinary magnitudes.

Therefore, if the  private  lands that are being studied for
historical  significance  and  nominated   to  the  National
Register  of  Historic Places are found to be  eligible  for
listing on the  National  Register  as  an expanded historic
district, these lands would be subjected  to the limitations
of the Code.  In that regard, a Virginia DOT official stated
that  any  property  within  a  newly  designated   historic
district  would  probably  not  be  considered  as  a bypass
construction site alternative.

Even though the regulations do not specifically require Park
Service  officials  to  notify  private  landowners  of  the
nomination  of  their  property  to the National Register of
Historic Places, the Park Service required its contractor to
notify private landowners of the historic resource study and
National  Register  nomination.  Also,  the  Park's  mission
states that Park officials should "provide opportunities for
citizens to participate  in the decisions and actions of the
Park Service."  Thus, we believe that Park Service officials
should work with their contractor  to  notify all landowners
who might be affected by the study and consider  any  of the
private  landowners'  concerns  in  determining  whether  to
include  their  property  in  the  nomination  to update the
Park's historic district.

Recommendations

We recommend that the Director, National Park Service,
ensure that the Superintendent of Manassas National
Battlefield Park:

     1.   Works  with  the   Commonwealth   of  Virginia  or
independently notifies and fully informs all  of the private
landowners of the historic resource study and the  plans for
the  expansion  of  the  historic district.  As part of  the
notification,  the Park Superintendent  should  ensure  that
private landowners  are  fully  briefed  and informed of the
effects of the Code of Federal Regulations  (23  CFR 771) on
property  that  has  been  designated  as part of a historic
district.

     2.    Considers   private  landowners'  complaints   or
concerns regarding their  property  in  the Park's plans for
nominating  land  to  be  included  in an expanded  historic
district.

National  Park  Service  Response  and Office  of  Inspector
General Reply

In the August 18, 1998, response (Appendix  4)  to the draft
report  from the Director, National Park Service,  the  Park
Service indicated  nonconcurrence with Recommendations 1 and
2, stating  that  the  recommendations  were  "superfluous."
Based  on  the  response,  we request that the Park  Service
reconsider its responses to  Recommendations  1 and 2, which
are  unresolved  (Appendix  6).  In its response,  the  Park
Service provided additional comments.   Those  comments  and
our replies are in Appendix 5.

Recommendation 1.  Nonconcurrence indicated.

     National  Park  Service  Response.   The  Park  Service
stated  that Park officials "and the contractor had notified
181 property  owners   about the project on May 22, 1998 and
had notified 79 property  owners  that their properties were
within the potential concurrent historic  district  on  June
30, 1998."

     Office  of  Inspector  General Reply.  We disagree that
the  recommendation  is superfluous.   The  notification  we
recommended is consistent  with  the  Park Service's mission
and is required by the statement of work  in the contract to
conduct  the  historic  resource  study.   The Park  Service
provided the letters identified in its response  only at the
exit  conference.  Therefore, we were unable to substantiate
that all  landowners  were  properly notified and briefed as
recommended.  While these actions  partially  respond to the
recommendation, the Park Service is requested to  provide  a
list  of  the landowners notified and its plans to brief and
inform all  landowners  of  the effects of the Code on their
property if it is designated as part of a historic district.

Recommendation 2.  Nonconcurrence indicated.

     National  Park  Service  Response.   The  Park  Service
stated that the Superintendent held an informal meeting with
property  owners  at  their request,  testified  before  the
Prince William Board of  Supervisors, and notified the local
newspapers about the project.

     Office of Inspector General  Reply.   We  disagree that
the recommendation is superfluous because the contractor did
not  fully  execute  the  provision  of  its contract  which
requires  consideration  of  landowners' views  in  deciding
whether to include their property  in a nomination to expand
the list of the National Register of  Historic  Places.  The
contract states  that "adjacent land and related  properties
[to  the  Manassas  National  Battlefield Park] may also  be
included in the revised nomination  provided  the respective
landowners  give  written  consent  for  inclusion of  their
property  within  an  expanded National Register  district."
(Emphasis added.)  The  Manassas  National  Battlefield Park
Superintendent should formally meet with property  owners as
a group and/or individually to address all of their concerns
about  the  inclusion  of  their  property  in  the  ongoing
nomination  of the land surrounding the Park to the National
Register of Historic  Places  and prepare an official record
of  the  meetings.   The  Park  Service   is   requested  to
reconsider its response to the recommendation.

                                                  APPENDIX 1

              ILLUSTRATION OF THE INTERSECTION
                OF ROUTES U.S. 29 AND VA 234*

The  only traffic signal within the Park is located  at  the
intersection  of  Routes  U.S.  29  and  VA  234.  This is a
standard square four-leg intersection owned and  operated by
the Commonwealth of Virginia.  As shown in the illustration,
the  north,  east,  and  west approaches are simple two-lane
roads with a single approach  lane.   No  separate  left  or
right  turn  lanes  are  provided on these three approaches.
The south approach had an  added right turn ramp in addition
to a single through left lane.


_______________________________
*Information and map  excerpted  from "Manassas National
Battlefield
Park Transportation Study," prepared  by Robert Peccia &
Associates,
Inc., June 1996, page 4-1.
                                                  APPENDIX 2


ILLUSTRATION OF HIGHWAYS WITHIN
MANASSAS NATIONAL BATTLEFIELD PARK*


_______________________________
*Information and map excerpted from "Manassas  National
Battlefield
Park  Transportation Study," prepared by Robert Peccia &
Associates,
Inc., June 1996, page D-21.

LAND USE PRACTICES AT MANASSAS NATIONAL BATTLEFIELD PARK,
1980 THROUGH 1997

Pursuant to  the  Code  of  Federal  Regulations (36 CFR
800.2),  historic  property  means  "any prehistoric  or
historic district, site, building, structure,  or object
included  in, or eligible for inclusion in, the National
Register."   Also  according  to  the Code, undertakings
means any project or activity that may result in changes
in the character of historic properties  in  order to be
covered  by the National Historic Preservation  Act  and
the Code.   The  project  or  activity must be under the
direct or indirect jurisdiction  of  a  Federal  agency.
Part   800   ("Protection   of   Historic  and  Cultural
Properties") of the Code states:

     Section   106   of   the   National   Historic
     Preservation  Act  requires  a  Federal agency
     head   with   jurisdiction   over  a  Federal,
     federally  assisted,  or  federally   licensed
     undertaking  to  take into account the effects
     of  the  agency's  undertaking  on  properties
     included  in  or  eligible  for  the  National
     Register  of Historic  Places  and,  prior  to
     approval of  an  undertaking,  to  afford  the
     Advisory  Council  on  Historic Preservation a
     reasonable  opportunity  to   comment  on  the
     undertaking.

The  Code  (36 CFR 800.5) lists the criteria  of  effect
that should be considered in deciding whether to approve
an undertaking as follows:

     (b) When  no  effect  is found.  If the Agency
     Official finds the undertaking  will  have  no
     effect  on  historic  properties,  the  Agency
     Official   shall  notify  the  State  Historic
     Preservation  Officer. . . .  Unless the State
     Historic Preservation  Officer  objects within
     15 days of receiving such notice,  the  Agency
     Official  is  not required to take any further
     steps. . . .

     (c) When an effect  is  found. If an effect on
     historic  properties  is  found,   the  Agency
     Official, in consultation with State  Historic
     Preservation Officer, shall apply the Criteria
     of  Adverse  Effect  ( 800.9(b)) to determine
     whether the  effect of  the undertaking should
     be considered adverse.

     (d) When the effect is not considered adverse.
     (1) If the Agency Official finds the effect is
     not adverse, the Agency Official  shall:   (i)
     Obtain   the   State   Historic   Preservation
     Officer's  concurrence  with  the finding  and
     notify  and  submit  to  the  Council  summary
     documentation,  which  shall be available  for
     public inspection; or (ii)  Submit the finding
     with necessary documentation  (  800.8(a)) to
     the  Council  for  a 30-day review period  and
     notify   the   State   Historic   Preservation
     Officer.

     (2)  If the Council does  not  object  to  the
     finding  of the Agency Official within 30 days
     of  receipt  of  notice,  or  if  the  Council
     objects  but  proposes changes that the Agency
     Official accepts,  the  Agency Official is not
     required  to  take any further  steps  in  the
     section 106 process  other than to comply with
     any   agreement   with  the   State   Historic
     Preservation Officer or Council concerning the
     undertaking.  If the   Council objects and the
     Agency Official does not  agree  with  changes
     proposed by the Council, then the effect shall
     be considered as adverse. . . .

     (e) When the effect is adverse.  If an adverse
     effect  on  historic properties is found,  the
     Agency Official  shall  notify the Council and
     shall   consult   with   the  State   Historic
     Preservation Officer to seek  ways to avoid or
     reduce  the  effects  on historic  properties.
     Either  the  Agency  Official   or  the  State
     Historic Preservation Officer may  request the
     Council  to  participate.   The  Council   may
     participate  in  consultation  without  such a
     request.

In   July   1995,   the  Advisory  Council  on  Historic
Preservation  and  the  National  Conference  of   State
Historic Preservation  Officers  approved  an  agreement
that   allowed  the  National  Park  Service  to  review
programmatic  exclusions  without  further review by the
Advisory Council or State Historic Preservation  Office.
According  to  the agreement, the following disturbances
or  undertakings   may   be   viewed   as   programmatic
exclusions:

      a. preservation   maintenance  (housekeeping,
     routine    and    cyclic   maintenance,    and
     stabilization). . .;

      b. routine grounds maintenance, such as grass
     cutting and tree trimming;

      c. installation of  environmental  monitoring
     units,   such  as  those  for  water  and  air
     quality;

      d. archeological  monitoring  and testing and
     investigations  of  historic  structures   and
     cultural     landscapes    involving    ground
     disturbing  activities   or   intrusion   into
     historic  fabric  for  research  or  inventory
     purposes;

      e. acquisition  of  lands  for park purposes,
     including additions to existing parks;

      f. rehabilitation  and widening  of  existing
     trails,  walks, paths,  and  sidewalks  within
     previously disturbed areas;

      g. repaving  of  existing  roads  or existing
     parking   areas  within  previously  disturbed
     areas;

      h. placement,  maintenance, or replacement of
     utility lines, transmission  lines, and fences
     within previously disturbed areas;

      i. rehabilitation work limited to actions for
     retaining   and  preserving,  protecting   and
     maintaining,  and  repairing  and replacing in
     kind  materials and features, consistent  with
     the Secretary  of the Interior's Standards for
     Rehabilitation    and     the     accompanying
     guidelines;

      j. health and safety activities such as radon
     mitigation  and  removal  of  asbestos,   lead
     paint, and buried oil tanks;

      k. installation   of   fire   detection   and
     suppression systems and security alarm systems
     and   upgrading  of  HVAC  [heating  and  air-
     conditioning] systems;

      l. erection  of  signs, wayside exhibits, and
     memorial plaques;

      m. leasing of historic properties.

We  reviewed  128  of the  Park  Service's  "Forms  for
Assessment of Actions  Having  an  Effect  on  Cultural
Resources"  and  determined  that  the 128 disturbances
were   approved   and  performed  in  accordance   with
applicable   regulations.    The   status   of   the128
disturbances is as follows: 9 were initially determined
by Park officials  to  have  an  adverse  effect on the
historic property and required prior approval  from the
State  Historic  Preservation  Office  and the Advisory
Council and were subsequently approved before  work was
initiated;  2 were classified by the Park as having  no
effect on the  historic resource and the Park Service's
Regional Archaeologist said that there were no historic
elements  present   and  that  the  property  had  been
previously disturbed;  and  117  were classified by the
Park  as programmatic exclusions because  the  property
was not on the list of classified structures maintained
by the  State Office and the Park.  Therefore, the Park
was not required  to  obtain  prior  approval  from the
State  Office.  Of 19 examples of disturbances and  the
justification  for each disturbance that were presented
in the "Forms for Assessment," the first 4 disturbances
were initially determined by the Park to have an effect
on historic property, the 5th and 6th disturbances were
considered  by the  Park  to  have  no  effect  on  the
historic resource,  and  the  13 remaining disturbances
were classified as programmatic exclusions.

-----------------------------------------------------------
|          Type of            |                           |
|Disturbance                  |Justification
                                                          |
-----------------------------------------------------------
|Stabilize the Sudley Post    |The structure was in poor  |
|Office.                      |condition and suffers from |
|                             |the impacts of weather and |
|                             |pest infestation.          |
-----------------------------------------------------------
|Construct new interpretive   |The proposed trail will open
|
|trail at Stuart's Hill       |a significant portion of the
|
|(Stuart's Hill Tract).       |battlefield to historical  |
|                             |interpretation.            |
-----------------------------------------------------------
|Dismantling of the Robinson  |The house was destroyed by |
|House.                       |arson.                     |
-----------------------------------------------------------
|Remove structure at Wheeler  |Remove derelict buildings  |
|House.                       |while protecting           |
|                             |archaeological resources   |
|                             |beneath existing structure.|
-----------------------------------------------------------
|Construct steps and          |The steps and boardwalk will
|
|boardwalk at Dogan House.    |help to improve public     |
|                             |access to the Dogan House. |
-----------------------------------------------------------
|Removal of several           |Numerous farm buildings are|
|nonessential buildings.      |deteriorating and present a|
|                             |safety hazard to the public.
|
-----------------------------------------------------------
|Demolish structure.          |To restore historic scene. |
-----------------------------------------------------------
|Removal of three foundations |Foundations did not exist  |
|of homes on lots 10-12       |during the battles of      |
|(Stuart's Hill Tract).       |Manassas.                  |
-----------------------------------------------------------
|Remove derelict structures   |Present a safety hazard to |
|which are in an extreme      |the public.                |
|state of disrepair.          |                           |
-----------------------------------------------------------
|Remove three tenant houses   |Houses were not present    |
|located on Pageland Lane.    |during battles of Manassas.|
-----------------------------------------------------------
|Demolition of house.         |House demolished because it|
|                             |is an intrusion on the     |
|                             |historic scene and is a    |
|                             |safety hazard.             |
-----------------------------------------------------------
|Demolish Quarters 2.         |To restore historic scene. |
-----------------------------------------------------------
|Remove building and concrete |Partially collapsed wooden |
|floor.                       |storage shed located in the|
|                             |front field.               |
-----------------------------------------------------------
|Remove building, concrete    |Return to natural terrain. |
|floors, footers, and gravel. |                           |
-----------------------------------------------------------
|Replace existing             |Structure was deteriorated.|
|deteriorated structure.      |                           |
-----------------------------------------------------------
|Remove buildings from new    |Presented a safety hazard. |
|lands.                       |                           |
-----------------------------------------------------------
|Remove derelict buildings    |Remove deteriorating farm  |
|and bury on site.            |buildings from newly       |
|                             |acquired lands.            |
-----------------------------------------------------------
|Remove dams and ponds.       |Cannot be maintained to Park
|
|                             |Service standards.         |
-----------------------------------------------------------
|New building replaces a      |New building will replace  |
|structure.                   |building that burned down. |
-----------------------------------------------------------

APPENDIX 3
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                                                   APPENDIX
5
                                               Page 1 of 17


NATIONAL PARK SERVICE COMMENTS
AND OFFICE OF INSPECTOR GENERAL REPLIES

Comments in the August 19, 1998,  response  (Appendix 4)
to our August 4,1998,  draft  report  from the Director,
National Park Service, and our replies  to  the comments
are provided as follows:

National Park Service Comments. The Park Service
stated:

     In your cover letter to the draft report, you
     state that at the exit conference on July 17,
     1998,  in  which  your  office  discussed the
     preliminary   draft   of  this  report   with
     National  Park  Service officials,  that  NPS
     [National Park Service]  officials "generally
     indicated  concurrence  with   the   report's
     findings    and    recommendations."     This
     statement is a material misrepresentation  of
     the  facts.  In truth, the Solicitor's office
     and NPS officials objected strenuously to the
     Office  of  Inspector  General's  preliminary
     draft  report  because of its utter disregard
     for the laws and  regulations  governing  the
     management  and  disposition of NPS lands and
     the  numerous  factual  inaccuracies  in  the
     preliminary  report.   Nearly  all  of  these
     deficiencies were  not corrected in the draft
     report, which is strikingly  similar  to  the
     preliminary draft.

Office  of  Inspector General Reply.    Our preliminary
draft report  included  two   findings, "Visitor Safety
and Protection" and "National Register Nomination," and
five recommendations to address  the  findings.  At the
July 17, 1998, exit conference,  Park Service officials
agreed  to implement the three recommendations  related
to visitor  safety  and  protection, stating that while
the Commonwealth of Virginia was solely responsible for
the intersection of Routes U.S. 29 and VA 234, the Park
Service would implement the  first two recommendations.
That is, it would work with the Commonwealth to improve
safety at the intersection, and  it would seek  funding
to conduct the study required by Public  Law 100-647 to
identify  options  to  close  the  intersection.   Park
Service    officials     responded    to   the    third
recommendation  by  agreeing  to warn visitors  of  the
intersection.  In that regard,  they requested our view
on alternative ways of informing visitors.   Also, Park
Service  officials  advised us that  they  had  already
implemented the first  recommendation  related  to  our
finding   on   the   National  Register  nomination  by
notifying the landowners  of their study in  May 22 and
June 30, 1998, letters.  They  further  stated that the
National  Park  Service's  contractor  was required  by
contract   to  respond  to  the  second  recommendation
relating to the National Register nomination, which was
to  consider   the   private  landowners'  concerns  in
deciding which property  to nominate for listing on the
National  Register of Historic  Places.   Specifically,
the contract stated:

     Adjacent   and  related  properties  [to  the
     Manassas National  Battlefield Park] may also
     be   included   in  the  revised   nomination
     provided  the  respective   landowners   give
     written   consent   for  inclusion  of  their
     property within an expanded National Register
     district. [Emphasis added.]

Based on these facts, we believe  that our draft report
accurately reflected the Park Service's  agreement with
our findings and recommendations.

Regarding  the  statement that most of the deficiencies
Park Service officials  cited  at  the  exit conference
were not corrected in the draft report, we  advised the
Park Service that we needed additional documentation to
support   the  officials'  statements  regarding  their
initiatives  to  improve safety at the intersection and
that  we wanted to  discuss  laws  and  regulations  as
contained  in  the  United  States Code (23 U.S.C. 138)
with the attorney from the Solicitor's office to ensure
our understanding of how Park Service officials thought
that this law should be presented in the report and how
the law related to visitor safety and protection.  Park
Service  officials  provided  us   only   with  limited
documentation  to support some of their comments.   One
document was an  October  1997  study  by  Virginia DOT
stating   that  funding was not available at that  time
for  the  Park Service  to  study  ways  to  close  the
intersection.    We   included  a  discussion  of  this
document  in  the draft report  (page  7).   They  also
provided copies of  two letters, dated May 22 and  June
30, 1998, both of which notified landowners of the Park
Service's study  related  to  the National  Register of
Historic  Places.   We advised Park  Service  officials
that we would  include  this action in our final report
(see Recommendations section  of current report at page
16).  After the exit conference, we  attempted on three
occasions    to  meet  with  the  attorney   from   the
Solicitor's  office    to  discuss  this  law  and  its
relevance to the findings  and  recommendations  in the
report.  The attorney was not available to meet with us
until   August   17,  1998,  1  month  after  the  exit
conference and 13  days  after  we had issued the draft
report.  Based on the interpretation  of the law by the
Office  of  Inspector  General's  General Counsel,   we
concluded that the law did not directly  apply  because
it   pertained  to the construction of  Federally aided
routes, and  a Virginia  DOT  official  advised us that
Commonwealth funds, not Federal aid, were to be used to
construct turning lanes at the intersection.  Moreover,
we  believe  that  completion  of the legally  required
study to find viable options to  close the intersection
would  be  more important if the law  (23  U.S.C.  138)
applies.  While  our  draft report  recognized the Park
Service's obligation to  protect park lands, we added a
general  discussion of the  Code (23 U.S.C. 138) to the
Background  section  to  further  clarify  the  report.
Finally,    we   talked   with   the    Department   of
Transportation   engineer   who  Park  officials   said
assisted  them  in developing alternatives  to  improve
safety at the intersection.   He  informed  us that his
analysis  was  not  approved by his superiors, was  not
reflected in a final  report,  and did not represent an
official Transportation safety analysis.

National Park Service Comments. The Park Service stated:


     The subject report, the  second  such  report
     requested  in the last year, was commissioned
     by [a] Congressman  .  .  .  to  evaluate how
     Manassas  National  Battlefield  Park  (MANA)
     officials      were      performing     their
     responsibilities for "resource management and
     land use practices, specifically  with an eye
     toward   any  abuses,  inconsistencies,   and
     public safety deficiencies."

Office of Inspector  General  Reply.  This statement is
incorrect.  Pursuant to the Inspector  General  Act  of
1978,  Offices  of  Inspector General routinely conduct
audits and investigations  based  on  requests from the
Administration, the Congress, Departmental managers and
their   staffs,   and   taxpayers.    The   Congressman
separately  requested,  but  did not "commission,"  the
Office of Inspector General to  perform  two reviews of
Manassas National Battlefield Park.  The first  request
was   that   we   should  independently  evaluate  Park
Service's responses  to a list of questions provided by
the Congressman concerning  maintenance  activities  at
the Park.  In this case, a report was not issued, but a
letter  transmitting  the  Park Service's responses was
provided to the Congressman.   The  second  request was
that  we  evaluate  the Park's resource management  and
land  use  practices  specifically   with  a  focus  on
administrative  abuses,  inconsistencies,   and  public
safety  deficiencies.   We  initiated an evaluation  in
response to this second request  because  it  concerned
public  safety.   This  report presents the results  of
that evaluation.

National Park Service Comments. The Park Service stated:


     I was particularly  pleased to note that your
     report found that the park superintendent and
     his   predecessors  did   not   abuse   their
     authority  regarding  land use practices.  In
     fact, the OIG [Office of  Inspector  General]
     draft  report  reviewed 128 land disturbances
     in the park from  1980 to 1997 and found that
     all  projects were in  full  compliance  with
     Federal  laws  and  regulations-a 100 percent
     compliance rate. . . .

     On page 5, second paragraph,  the  OIG  draft
     report states that your "office reviewed  128
     land  disturbances that occurred from 1980 to
     1997,  and  determined  that  park  officials
     generally  complied  with  . . . 36 CFR 800."
     The report then refers to appendix 3.  In the
     appendix,  OIG  staff  determined  that  park
     officials  were in full compliance  with  the
     regulatory requirements  under 36 CFR 800 for
     all  128  projects.   Further,  there  was  a
     consistency in park management  in regards to
     resource  management  projects from  1980  to
     1997.  There was no evidence  of any abuse of
     administrative      authority      by     the
     superintendent  or his subordinates based  on
     the analysis of the  OIG  of  these  128 land
     disturbances.

     Since the letter from [the] Congressman . . .
     specifically  requested that the OIG evaluate
     "the park's resource  management and land use
     practices, specifically  with  an  eye toward
     administrative  abuses, inconsistencies,  and
     public safety deficiencies,"  the OIG staff's
     findings that park management fully conformed
     to  all  applicable regulations for  all  128
     projects is  quite  significant.   Thus,  the
     comment   that   "Park   officials  generally
     [emphasis  added  by  Park Service]  complied
     with the Code of Federal  Regulations  . . ."
     should  be  changed to "fully" complied.   In
     addition,  the   OIG  should  state  that  no
     evidence of abuse or inconsistency was found.

Office  of Inspector General  Reply.   Our  review  was
limited   to   determining   whether   the   128   land
disturbances  were  properly approved and documented on
the  Park Service's "Form  for  Assessment  of  Actions
Having  an Effect on Cultural Resources."  The scope of
the  evaluation   did   not  include  identifying  land
disturbances that were not  documented  on  this  form.
Thus,  we  could  not support a statement that the Park
Service fully complied with requirements regarding land
disturbances in the  Code.   However,  we  have added a
statement in the report (page 9) that to the  extent of
our  review, we determined that Park officials complied
with the  Code  of  Federal  Regulations  (36  CFR 800)
related  to  the  protection of historic property.   We
also  added  a statement  that  based  on  our  limited
review, we found  no  evidence of administrative abuses
or inconsistencies.

National Park  Service Comments. The Park Service stated:

     It [Office of Inspector General draft report]
     fails to apply  the legal test of 23 USC 138
     to  the  taking  of  park  land  for  highway
     projects.  This statute  provides  that there
     shall  be  no  use  of  park  land  for  road
     projects,  unless  there  is  no feasible and
     prudent alternative to the use  of  that park
     land.   Although  this serious oversight  was
     brought to the attention  of  OIG  [Office of
     Inspector   General]   staff   at   the  exit
     interview, the OIG draft report continued  to
     ignore this critical Federal law. . . .

       As I read the report, your staff has failed
     to   heed   the   explanations   of  the  law
     repeatedly provided by the Solicitor's office
     and  NPS  [National  Park Service] officials.
     The OIG should modify  the report properly to
     reflect  the pertinent laws  and  regulations
     relating to the management of public land, as
     well  as the  duty  of  the  Commonwealth  of
     Virginia  to  manage  state  roads and notify
     adjacent property owners. . . .

     On  page  3  of  the  OIG  draft  report  and
     following,   the   statement  that  "Manassas
     National Battlefield  Park  officials did not
     grant approval to the Virginia  Department of
     Transportation  (VDOT)  to construct  turning
     lanes to improve safety at  the  intersection
     of  Routes U.S. 29 and VA 234 . . ."  assumes
     that turning lanes are the only solution that
     would  improve  safety  at  the intersection.
     This  statement  is  misleading   and  wrong.
     During  the exit interview and the course  of
     the  investigation,  NPS  officials  and  the
     Solicitor's office stressed that the standard
     binding upon Federal officials concerning the
     taking  of  park land for road projects is 23
     USC 138.  The  construction of turning lanes
     requires  the  taking   of  park  land.   The
     statute states that park  land  can  only  be
     taken  if  there  is  no feasible and prudent
     alternative.  The OIG draft report completely
     ignores this standard and  creates  the false
     impression  that  NPS  needs  to do something
     further to discharge its duty.

     Further, Section 106 of Historic Preservation
     Act  of  1966  (16 USC 470), as amended,  NPS
     Organic Act of 1916  (16  USC  1),  and  MANA
     [Manassas    National    Battlefield    Park]
     amendments  of 1988 (P. L. 100-647) all place
     restrictions  on Federal officials concerning
     the use of park  land  for  projects  such as
     this.   In  fact,  the  1988  Act directs NPS
     officials  to  find  ways  to  move  non-park
     traffic  out  of the park not encourage  more
     traffic,  as  turn   lanes  would  do.   Park
     management acted properly  by  not attracting
     non-visitor use of public roads that transect
     the park.

Office of Inspector General Reply.  Based  on  a review
by  the  Office of Inspector General's General Counsel,
we concluded  that  23 U.S.C. 138 did not apply in this
situation.  First, we  did  not  advocate any taking of
Federal property but rather described  the actions that
the Park Service and Virginia DOT had proposed  or  had
taken regarding safety at the intersection.  Second, 23
U.S.C.  138,  part  of  the  Federal-Aid Highway Act of
1966, as amended, applies only  to  Federal aid highway
projects.  A Virginia DOT official advised  us  that no
decision  had  been made to use Federal aid to add  the
turning lanes to the intersection of Routes U.S. 29 and
VA  234.   Further,   on  August  10,  1998,  the  Park
Service's attorney from  the  Office  of  the Solicitor
stated that the Park Service was required by  23 U.S.C.
138 to demonstrate that there are feasible and  prudent
alternatives to the use of park property.  However, the
attorney  further  stated  that  he  was not aware that
Virginia DOT had not planned to use Federal  aid  funds
to   add   the   turning  lanes  to  the  intersection.
Moreover, this statute  imposes  an  obligation  on the
Secretary  of Transportation, not the Secretary of  the
Interior or  the  Park  Service,  to  determine whether
there are no prudent and feasible alternatives  to  the
use  of  park  land  prior  to approving projects which
require the use of such lands.   In  carrying  out  the
policy of Section 138, the Secretary of Transportation,
"in  cooperation with the Secretary of the Interior and
appropriate State and local officials, is authorized to
conduct  studies  as  to  the most feasible Federal-aid
route. . . ."

More importantly, we noted  that  the  Park Service had
not completed the study required by Public Law 100-647,
which was to "specifically consider and  develop  plans
for closing routes U.S. 29 and VA 234 that transect the
Park  and include analysis of timing and method of such
closures and of means to provide alternative routes for
traffic  now  transecting  the  Park."   The  study was
required  to  be  completed  by  November  1989.   Park
Service  officials  stated that they could not complete
the study because they  did not have funding.  However,
by not conducting the required  study, the Park Service
caused  delays  in identifying acceptable  options  for
improving safety at the intersection.

National Park Service Comments. The Park Service stated:

     It [the  draft  report]  fails  to  place the
     primary  responsibility for safety on  public
     roads with the Commonwealth of Virginia.  It,
     instead,     incorrectly      places      the
     responsibility for safety on state roads with
     NPS  [National Park Service].  The NPS has no
     jurisdiction  over  the  roads  in  question.
     Public  safety  on  state roads is under  the
     exclusive jurisdiction of the Commonwealth of
     Virginia.   Thus,  it  is  the  duty  of  the
     Virginia Department of Transportation  (VDOT)
     to   establish  a  safe  public  road  system
     throughout   the  Commonwealth  of  Virginia.
     Public Law 100-647  places  responsibility on
     the  Park  Service  to  conduct  a  study  to
     identify alternatives to close Routes U.S. 29
     and  VA  234.  .  . .  On page 7, first  full
     paragraph,  the  OIG   [Office  of  Inspector
     General] draft report again  makes  the false
     statement  that NPS officials are responsible
     for notifying  visitors  of  potential safety
     problems      at     the     state-controlled
     intersection.  Please delete this statement.

Office of Inspector  General  Reply.   The draft report
stated  that the Park Service's mission and  its  "Loss
Management  Control  Guidelines" require Park officials
to consider visitor safety  in  managing the Park.  The
mission  includes  the statement that  "the  saving  of
human  life  will  take   precedence   over  all  other
management actions. . . .  The Park Service  will  work
cooperatively  with  other  Federal,  state,  and local
agencies,  organization,  and individuals to carry  out
this  responsibility."   While   we   agree   that  the
Commonwealth  of  Virginia  owns the public roads,  the
Park  Service,  through  its  mission   and  management
policies, has an implicit responsibility  for safety in
the Park, including the intersection of Routes  U.S. 29
and  VA  234,  which  are  in  the  Park  and part of a
published Park tour.  We infer from the Park  Service's
comments   that  the  Park  Service   should  not  warn
visitors  of   the   safety  problems  "at  the  state-
controlled intersection."  To the contrary, we believe,
as stated in the report (page 7), that the Park Service
has  a  responsibility  to   warn   visitors   "of  the
potentially hazardous intersection" in accordance  with
its management policies and guidelines.

National Park Service Comments. The Park Service stated:

     On  page  7,  first  full  paragraph, the OIG
     [Office  of Inspector General]  draft  report
     criticizes park management for not installing
     a  sign  to   warn   pedestrians   about  the
     potential   hazard   of  crossing  the  state
     highway.   As  NPS  [National  Park  Service]
     officials  stated  at  the   exit  interview,
     traffic safety engineers from  FHWA  [Federal
     Highway Administration] and VDOT have advised
     park  management  not  to  install  the sign,
     because  it could serve as an invitation  for
     visitors to  place  themselves  in  peril  by
     crossing  the  road.   Further, the safety of
     pedestrians walking on the  state  roadbed is
     within the legal domain of VDOT.

Office of Inspector General Reply.  Park  officials did
not  provide  any documentation to support their  claim
that traffic safety  engineers from the Federal Highway
Administration and Virginia  DOT  advised  them  not to
install  a sign to warn pedestrians about the potential
hazard of  crossing  a  state  highway.  Regardless, we
were not critical of the Park Service for not posting a
sign,  nor  did  we  recommend that  it  post  a  sign.
Instead, we reported that  the  Park  Service's traffic
study  included a recommendation that signs  should  be
posted at  a  cost  of  $1,250  "at  various  locations
throughout  the  Park"  to  warn visitors of the  "high
accident location."  We also  reported  that  the  Park
Service  stated that it had not warned visitors because
it believed  that  the Commonwealth of Virginia and not
the  Park  was  responsible  for  the  safety  of  Park
visitors at the intersection  because the state was the
owner of the highways.  We concluded that regardless of
who  owned  the  highways  and  the   Commonwealth   of
Virginia's   responsibility,   the   Park  Service  was
responsible  for  visitor  safety consistent  with  its
mission statement and guidelines  and  Park  activities
require the use of the intersection of Routes  U.S.  29
and  VA  234, which is in the center of the Park and is
included on a driving tour of the Park.  Also, visitors
use  the  intersection   to  enter  and  exit  roadside
interpretive areas and the  small  parking lot at Stone
House  directly  adjacent  to  the  intersection.    We
recommended that Park Service officials inform visitors
of  the  high  accident intersection and advise them to
use caution in and around the intersection to give Park
Service officials  maximum flexibility to determine the
best method of accomplishing  such.   At  the  July 17,
1998,  exit  conference, we suggested that Park Service
officials  consider  notifying  visitors  of  the  high
accident  intersection  at  Stone  House,  the  Visitor
Center, and other Park-owned locations.


                                          APPENDIX

                                         Page 1 of


National Park Service Comments. The Park Service stated:

     It  [the  draft report] fails to place proper
     emphasis on  the  exclusive responsibility of
     the  Commonwealth  of   Virginia   to  notify
     private  landowners  of adjacent property  of
     any   concurrent  Federal/private   completed
     nominations   to  the  National  Register  of
     Historic Places, as required in 36 CFR 60.10.
     . . .

     On page 9 and following,  the  OIG [Office of
     Inspector General] draft report  states "that
     Manassas National Battlefield Park  officials
     were  not  required  by law or regulation  to
     notify  landowners  of the  Park's  plans  to
     conduct a historic resource study and prepare
     a nomination to update  the Park's listing on
     [in]  the  National  Register   of   Historic
     Places."   The  report  should  have  stopped
     right there.  However, the OIG report ignores
     the  legal responsibility of the Commonwealth
     of  Virginia,  and  instead  criticizes  park
     management and the park contractor, preparing
     the National  Register  nomination,  for  not
     notifying enough property owners.

Office  of  Inspector General Reply.  We disagree  with
the Park Service's  statement  that  our  draft  report
"ignore[d]"    the    legal   responsibility   of   the
Commonwealth of Virginia.   In  our  draft report (page
12), we quote, in part, the Code of Federal Regulations
(36 CFR 60.10).  The Code states:

     When  a  portion  of the area included  in  a
     Federal nomination  is  not  located  on land
     under the ownership or control of the Federal
     agency,  but  is  an  integral  part  of  the
     cultural  resource,  the completed nomination
     form  shall  be sent to  the  State  Historic
     Preservation  Officer   for  notification  to
     property owners, to give  owners  of  private
     property  an  opportunity  to  concur  in  or
     object  to the nomination, to solicit written
     comments  and  for  submission  to  the State
     Review Board. [Emphasis added.]

We followed this quote in the report with  a  statement
that  recognized the legal responsibility of the  state
rather  than  the  Federal Government to notify private
landowners.   We also  disagree  that  we  should  have
stopped the report  at  recognizing the Commonwealth of
Virginia's responsibility  because   the contract which
was awarded by the Park Service to conduct  a  historic
resource   study  required  the  contractor  to  notify
landowners within the area.  Thus, the Park Service had
a responsibility  to ensure that the contractor adhered
to its statement of  work  and notified the landowners.
At the exit conference and in  comments  to  the  draft
report  made by Park Service officials, these officials
advised us that they had implemented our recommendation
by notifying  all  pertinent  landowners of their study
through  May 22 and June 30, 1998, letters.

National Park Service Comments. The Park Service stated:

          On  page  1  of  the   OIG   [Office  of
          Inspector  General]  draft  report,  the
          second  paragraph  should  be eliminated
          because   the   NPS   50  "Loss  Control
          Management Guidelines" impose no duty on
          NPS  units to assume any  responsibility
          of the  states  for  the  management  of
          safety  on  state  roads.   In this case
          safety on public roads is solely  within
          the jurisdiction of the Commonwealth  of
          Virginia. . . .

          On  page 5, the first full paragraph and
          following  text of the OIG draft report,
          there is an  assertion  that NPS mission
          statement and NPS 50 place the burden on
          NPS officials to protect  "the  visiting
          public  from  recognized hazards."   The
          NPS 50 does not  and  cannot  place  any
          burden  on  NPS officials for the safety
          of motorists  on  state  roads.  Despite
          the jurisdictional distinction  of  laws
          and    regulations    that   place   the
          responsibility of highway  safety solely
          on the Commonwealth of Virginia, the OIG
          draft   report  incorrectly  lays   this
          responsibility  on  NPS  officials.    I
          strongly  suggest  that any reference to
          NPS 50, or, for that matter, any Federal
          law, regulation, or guideline as binding
          upon  NPS  officials  in   this  context
          should  be eliminated.  That  assumption
          simply is wrong.

Office of Inspector  General  Reply.   The "Guidelines"
states  that  the  Park  Service's  regions  and  parks
"should  establish  a  public   safety   program   that
minimizes  the  potential  for  injury,  illness, death
and/or  property  damage to the public while  they  are
visiting Park Service  facilities."   Section  A of the
"Guidelines"  states that "every effort should be  made
to identify the  hazards  in  the  park/area  that have
caused or have the potential to cause, injury, illness,
death   or  property  damage  to  park  visitors."   In
addition, Section G states that "all areas will provide
any special  materials, signs and programs to alert the
public of potential  dangers  and brochures specific to
the  area should contain safety  messages  that  direct
attention  to special hazards or attractions that could
be potentially  hazardous  to  the visitor."  Also, the
Park  Service's  mission  statement   generally  places
responsibility  on Park Service officials  to  consider
"the saving of human  lives"  over all other management
actions.  The mission statement  requires that the Park
work  "cooperatively  with  other federal,  state,  and
local agencies, organizations  and individuals to carry
out this responsibility."  Furthermore, Public Law 100-
647  places  direct  responsibility   on  Park  Service
officials  to  identify  options  to  close   the  high
accident  intersection "of Routes U.S. 29 and VA  234."
Considering  these  requirements,  we  recommended that
Park  Service officials (1) work with the  Commonwealth
of Virginia to determine a mutually acceptable approach
to improve  safety  at  the  intersection,  (2)  pursue
funding  to identify options to close the high accident
intersection,   and   (3)   inform  visitors  that  the
intersection is a "high accident location."

National Park Service Comments. The Park Service stated:

               On page 2 of  the  OIG  [Office  of
               Inspector  General]  draft  report,
               the  assertion  of  there being  no
               prior reports is false.  On January
               28,  1998,  OIG  issued   a  letter
               report  (I-IN-NPS-001-98) to  [the]
               Congressman  . . .  and transmitted
               that report to  NPS  [National Park
               Service] on March 25,  1998.   That
               letter     report     caused    the
               Congressman to request  the  second
               report.

          Office of Inspector General Reply. The Park
          Service's comments are incorrect. The January
          28, 1998, letter was not a report but   a
          transmittal of the Park Service's response to
          the   Congressman's    questions    regarding
          maintenance  activities  at Manassas National
          Battlefield  Park,  for  which   we  provided
          oversight.   The report number cited  in  the
          Park  Service's  response  is  an  Office  of
          Inspector  General assignment number that was
          provided  to   the  Park  Service  when  this
          evaluation was initiated.  In fact, the Prior
          Audit Coverage section  of this and any other
          report  addresses  the status  of  issues  in
          prior audit reports  that  directly relate to
          the objective of the report.   Thus,  even if
          the  letter was a  report, it would not  have
          been included  in  the  Prior  Audit Coverage
          section  because  the  issue  of  maintenance
          activities  did  not  relate to this report's
          objective   of   determining   whether   Park
          officials  (1) took  any  action  to  improve
          safety at the  intersection of Routes U.S. 29
          and VA 234, (2)  properly  planned to include
          land  surrounding  the Park in  the  National
          Register of Historic Places, and (3) executed
          land use practices that  were  in  accordance
          with applicable requirements.

National Park Service Comments. The Park Service stated:

               On page 2 (and elsewhere in the OIG
               [Office of Inspector General] draft
               report)  this  document is referred
               to as an "audit."   According  to 5
               USC Appendix (The Inspector General
               Act   of  1978,  as  amended),  the
               standards    for   an   audit   are
               established  by   the   Comptroller
               General   of   the  United  States.
               Thus,     "Government      Auditing
               Standards,  1994  Revision," should
               have  been the standards  for  this
               audit and report.

          Office of Inspector General  Reply.  The Park
          Service's comments are inaccurate. We performed
          an evaluation, not an audit.  Evaluations are
          governed  by  the  "President's   Council  on
          Integrity  and  Efficiency  Quality Standards
          for Inspections," not the General  Accounting
          Office's   "Government  Auditing  Standards."
          The standards for inspections require that we
          consider  prior audit and evaluation coverage
          in planning  and  performing  our evaluation.
          We  used the word "audit" only in  the  Prior
          Audit Coverage section (page 2) of the August
          4, 1998, draft report.

National Park Service Comments. The Park Service stated:

               In    fact,    based    upon    the
               recommendations  of  traffic safety
               experts,    NPS   [National    Park
               Service]  staff   have  proposed  a
               number  of  feasible   and  prudent
               alternatives  to  VDOT  to  improve
               safety at the intersection  that do
               not  require  the  taking  of  park
               land.  The NPS officials are in the
               process  of  moving the parking lot
               at Stone House to a new location to
               the  east side  of  the  structure.
               All traffic  safety engineers agree
               that this move is the most critical
               safety    improvement    for    the
               intersection.   Again, although NPS
               officials   stressed   this   major
               safety improvement, the OIG [Office
               of Inspector  General] draft report
               ignored this information. . . .

                Further, traffic  safety engineers
               from     the     Federal    Highway
               Administration  (FHWA)  agree  with
               the  NPS  approach   to   improving
               safety  at  the intersection.  They
               suggested other  measures,  such as
               lowering  the speed limit, lowering
               the grade of  the north approach on
               VA 234 by 1 to  2  feet, increasing
               law   enforcement   of  speed   and
               turning     movements    at     the
               intersection,   and  other  traffic
               calming actions, that would further
               improve safety at  the intersection
               without  the taking of  park  land.
               In  the  professional   opinion  of
               these FHWA officials, added turning
               lanes   at  the  intersection   are
               related to  capacity,  not  safety.
               The  clear inference is that VDOT's
               goal is  to  increase  vehicle flow
               and capacity, not merely to address
               safety.  Moreover all of  the above
               measures  are  feasible and prudent
               alternatives to  the  use  of  park
               land as proposed by VDOT.

          Office of Inspector General Reply. During the
          review, we requested information from Manassas
          National Battlefield Park officials regarding
          safety  improvements  at the intersection  of
          Routes  U.S. 29 and VA 234.   Park  officials
          stated that  the  sequencing  of  the traffic
          signals  at  the  intersection  was the  most
          significant improvement they would allow, and
          they did not provide any support  for  the 18
          alternatives listed (pages 32 and 33) as part
          of their comments on the draft report.   Park
          Service  officials  only  advised us of these
          alternatives  at  the  exit  conference   and
          agreed  to  provide  us  with the name of the
          Federal   Highway   Administration    traffic
          engineer   and  a  copy  of the report he had
          prepared   to  support  these   alternatives.
          Despite this  agreement  and  our  subsequent
          request,  Park  Service  officials  did   not
          provide  the  name  of  the  engineer  or the
          report.       Without     this     additional
          documentation,  we  did  not  consider  these
          comments   in  preparing  the  draft  report.
          However,    the     U.S.     Department    of
          Transportation  engineer  who Park  officials
          said assisted them in developing alternatives
          to improve safety at the intersection told us
          that  his  analysis was not approved  by  his
          superiors  and  that  it  therefore  did  not
          represent an  official  Transportation safety
          analysis.

National Park Service Comments. The Park Service stated:

               The  NPS  [National  Park  Service]
               officials,  on numerous  occasions,
               and   at   the  recommendation   of
               traffic  safety   engineers,   have
               recommended  sequencing the traffic
               lights    to    control     turning
               movements.   While  the OIG [Office
               of Inspector General]  draft report
               references  this  suggestion,   and
               discusses  it  in  some  detail, it
               quotes an unnamed VDOT official  as
               stating that "traffic would come to
               a  standstill  .  .  ." (p. 6).  In
               other words, the VDOT official does
               not  dispute that light  sequencing
               will   improve    safety   at   the
               intersection, but is more concerned
               that traffic would not move as fast
               and  efficiently  as  he/she  would
               like.

          Office of Inspector General Reply. The draft
          report stated that a Virginia DOT official
          stated that "sequencing the traffic signals
          in this manner at Routes U.S. 29 and VA 234
          would cause traffic to come to a standstill
          due to the large volume of traffic that would
          be waiting during multiple red signal phases."
          According   to  the  Virginia  DOT  official,
          driver  frustration  and  delays  are  common
          causes of  accidents.   Also,  the  Code  (23
          U.S.C. 138) states:

In  carrying  out  the national policy declared in
this section the Secretary [of Transportation], in
cooperation with the Secretary of the Interior and
appropriate   State  and   local   officials,   is
authorized  to conduct  studies  as  to  the  most
feasible Federal-aid  routes  for  the movement of
motor vehicular traffic through or around national
parks  so  as  to  best  serve  the needs  of  the
traveling  public  while  preserving  the  natural
beauty of these areas.  [Emphasis added.]

Although there are apparently many  alternatives  that could
be proposed to improve safety at the intersection of  Routes
U.S. 29 and VA 234 without improving traffic conditions, the
needs of the traveling public should be served.  Thus,  none
of  the Park Service's alternatives were mutually acceptable
because  Virginia DOT officials said that they believed that
the alternatives  could  exacerbate not alleviate the safety
problem at the intersection.  Recognizing this disagreement,
we recommended that the Park  Superintendent  "work with the
Commonwealth  of Virginia's Department of Transportation  to
determine a mutually  acceptable  approach to improve safety
at the intersection. . . ."

     National Park Service Comments. The Park Service stated:

     At the exit interview, NPS
     [National Park Service] officials cited
     the   recommendations   of   these  FHWA
     [Federal     Highway     Administration]
     officials,  gave  the  OIG  [Office   of
     Inspector  General] the name of the lead
     traffic safety  engineer,  and asked the
     OIG   to  contact  him.   Although   OIG
     officials stated that they would contact
     him,  they  did  not  make  contact  nor
     consult with the FHWA safety engineer.

     In short,  the  section of the OIG draft
     report  that  addresses  safety  at  the
     intersection, vis  a  vis modifications,
     ignored  Federal  laws  and  regulations
     binding    upon    Federal    officials.
     Further,   it   virtually   ignored  the
     significant efforts of NPS officials  to
     improve  safety, and failed to interview
     an impartial traffic safety engineer who
     would have  confirmed that NPS officials
     have acted responsibly  on  the issue of
     safety   at   the  intersection.    This
     section of the  OIG  draft  report is so
     fundamentally   flawed   it   must    be
     completely   revised,   to   ensure  the
     accuracy of the final report.

Office of Inspector General Reply. Park   Service
officials  did  mention  at    the  July 17, 1998,
exit conference that a traffic safety  engineer at
the   U.S.   Department   of   Transportation  had
performed  an assessment of safety  conditions  at
the  Park.   The   Department   of  Transportation
engineer who Park officials said  had  performed a
safety  assessment and assisted them in developing
alternatives to improve safety at the intersection
told us that  his analysis was not approved by his
superiors and that  it therefore did not represent
an  official Transportation  safety  analysis.   A
documented  transportation safety assessment study
was  not provided  by  the  Park  Service  or  its
attorney from the Office of the Solicitor.

National Park Service Comments. The Park Service stated:

     On  pages  3  and  4, the OIG [Office of
     Inspector  General] draft  report  cites
     statistics  from   VDOT   and   the  NPS
     [National    Park   Service]   "Manassas
     National        Battlefield        Park,
     Transportation   Study   (NPS   Study)."
     Statistics from the  NPS  study  relates
     traffic  statistics  to  Prince  William
     County, which is far more relevant.  For
     example, relating the accidents for this
     intersection  to  the  rest of Virginia,
     where  in  many  rural  areas  there  is
     minimal  traffic and minimal  accidents,
     is not particularly  relevant  for  this
     geographical  area  of  the State.   For
     example, this intersection  is  not even
     in    the    top    10   for   dangerous
     intersections in Prince  William  County
     (Potomac News April 13, 1995).  Further,
     it  is  the safest intersection on Route
     234 between  the  park  and  the City of
     Manassas.

Office of Inspector General Reply. We infer from the
Park  Service's  comments   that the Park  Service
believes that the intersection  is  not dangerous.
We    disagree,   since   this   belief   directly
contradicts  the  Virginia DOT's statistic and the
Park Service's traffic  study  for  which  it paid
$112,000.   In that regard, the study stated  that
this  "intersection   had   the  largest  accident
cluster within the Park."  The  study  stated that
"it  is  believed  that the accident rate for  the
Routes U.S. 29 and VA 234 intersection is actually
greater than calculations  indicate"  because many
accidents on Routes U.S. 29 and VA 234 were likely
a result of congestion caused by the intersection.
The  Virginia DOT statistic  and the study  showed
that 301  accidents  occurred in Manassas National
Battlefield Park between  1991  and  1997,  288 of
them on Routes U.S. 29 and VA 234, and only 13  on
all other Park roads.  According to the study, the
accidents  resulted  in  three  fatalities  and at
least  176  injuries and 134 incidents of property
damage.   The   report  included  observations  of
safety  concerns,  including   (1)  potential  for
rear-end   accidents   resulting   from   vehicles
approaching the end of a long curve extending back
from   the   intersection;   (2)  potential  angle
accidents   caused   by   conflicting   turns   by
southbound, northbound, and  westbound  traffic at
the intersection; (3) potential rear-end accidents
at  the  intersection resulting from Park visitors
attempting to enter or exit "roadside interpretive
areas"; and  (4) pedestrian safety attributable to
a   lack  of  "pedestrian   facilities"   at   the
intersection.    We  are  concerned  by  the  Park
Service's attempts  to  de-emphasize  the  serious
safety  problems  by stating that the intersection
"is  not  even  in  the   top   10  for  dangerous
intersections in Prince William County.   .  .  ."
Park   Service  officials  are  required  by  Park
Service    mission    statement   and   management
guidelines to address safety  in  the Park.  Also,
Public  Law 100-647 requires the Park  Service  to
identify  options  to  close Routes U.S. 29 and VA
234 in the Park.  Further,  according  to the Park
Service's  transportation  study, the intersection
of Routes U.S. 29 and VA 234 is the most dangerous
intersection included on a driving tour within the
Park that is visited by over  one  million  people
per year.

National Park Service Comments. The Park Service stated:

On  page  4,  the  OIG  [Office  of Inspector
General] draft report states that 10 visitors
complained  about the safety on roads  within
the park.  What  the report did not state was
that  492 visitors  were  surveyed  in  1995;
thus, and  only .02 percent commented on road
safety.

Office of Inspector General Reply. The draft report
did  not state that "10 visitors complained  about
the safety  on  roads  within the Park."  Instead,
the report stated that "we  reviewed the responses
to a specific question (`what  did  you like least
about your visit to Manassas National  Battlefield
Park?')" within the questionnaire and compiled the
comments  that  were specifically related  to  the
intersection of Routes  29  and  VA 234.  Although
there  were various types of complaints  regarding
safety,  we  noted that 10 visitors indicated that
excessive traffic  speed  and  noise and dangerous
conditions existed in and around the intersection.
We have added a statement (page  6)  that  the  10
visitors   represented  2  percent  of  the  total
visitors surveyed.

National Park Service Comments. The Park Service stated:

On page  5,  middle of second paragraph,
the OIG [Office  of  Inspector  General]
draft   report   quotes  VDOT  officials
stating that "about 8 feet of additional
right-of-way on the  west  side  of  the
road  .  . ." would be required to widen
the intersection.  As NPS [National Park
Service] officials  noted  at  the  exit
interview,  the  plans submitted by VDOT
to NPS would require  about  8 feet  for
the  actual  finished  roadbed, but they
would also require an additional  1 to 2
acres of land for the required cut-backs
into   park  land  to  accommodate  that
widening.   The report should be changed
to reflect the correct amount of acreage
that  will  be  required  for  the  turn
lanes.

Office of Inspector General Reply. The  draft report
states  that  a  Virginia  DOT official who  is  a
traffic engineer provided a written statement with
the supporting proposed plans for the intersection
which said that "all road widening  on U.S. 29 can
be  accomplished  with  the existing Virginia  DOT
right-of-way and the widening  on VA 234, north of
the  intersection would require about  8  feet  of
additional  right-of-way  on  the west side of the
road and additional right-of-way at the corners of
the intersection for traffic signals," for a total
of about .2 acres.  We requested that Park Service
officials provide support for their statement that
the  Virginia  DOT  plan  needed  1  to  2  acres.
However, we have not received any documentation.

National Park Service Comments. The Park Service stated:

  On  page  6,  second paragraph, the  OIG
[Office  of  Inspector   General]  draft
report discusses P. L. 100-647, and more
specifically,  10004, which directs the
Secretary of the Interior  to  study and
find  the  means to close Routes 29  and
234  through   MANA  [Manassas  National
Battlefield Park].  The OIG draft report
further states that  NPS  [National Park
Service]  has not completed  the  study,
nor closed  the roads.  These statements
are technically  correct, but misleading
because  Congress authorized  but  never
appropriated  the funds required for the
study.   Thus,  the   OIG  draft  report
misrepresents  the facts.   Further,  as
NPS  officials  explained  at  the  exit
interview, the characterization  of  the
OIG draft report that NPS officials have
done  nothing  to fulfill this provision
of the legislation is incorrect.

From the period  1995  to  present,  the
following  has been accomplished: 1) The
NPS  study  referenced  in  the  report,
contracted in  1995,  completed in 1996,
was designed to study traffic within the
park,   and  make  recommendations   for
improving  traffic safety on park lands.
A   list   of  completed   or   proposed
improvements  was  submitted to the OIG,
and is attached to this  response.    2)
VDOT   agreed   to   conduct   a   study
identifying  possible alternative routes
as  part of the  I-66  Major  Investment
Study.   This  study was started in 1996
and completed in 1998, identifying three
potential  alternative   alignments  for
Routes 29 and 234.  A copy of this study
was requested by OIG staff  at  the exit
interview,  provided  by  NPS officials,
but  not  referenced  in  the OIG  draft
report.  This was the second step toward
finding a permanent solution to commuter
traffic  in  the  park.  3) The  NPS  is
responsible for funding  the next phase,
which   will   determine   a   preferred
alternative, with minimal design, and an
Environmental  Impact  Statement.   This
study will cost between  $1.5  [million]
and  $2.0  million  and a funding source
will have to be identified.  The  report
should reflect NPS efforts to accomplish
the  legislative mandate to close Routes
29 and 234 through the park.

Office of Inspector General Reply. At the July 17,
1998,  exit  conference,  we  asked  Park  Service
officials if and when the funds for the study  had
been  requested  from  the Congress.  Park Service
officials  did not provide  any  documentation  to
show that the funds were requested  but provided a
Virginia DOT study which stated that the funds for
the Park Service  study  to close the intersection
were not provided.  The draft  report  stated that
"according  to  the  Act,  the  study should  have
determined when and how to close  Routes  U.S.  29
and   VA  234  by  November  10,  1989."   In  its
comments,  the Park Service did not provide a time
frame  in  which   the  required  study  would  be
completed.  As such, almost 10 years after the Act
was passed, the Park  Service had not completed or
requested funding for the required study.

National Park Service Comments. The Park Service stated:

On page 13, the OIG [Office  of Inspector General]
draft report cites 23 CFR 771.   The  draft report
should   have   referenced  36  CFR  60  as  well.
Although  NPS [National  Park  Service]  officials
explained in  some detail the relationship between
listing  in  the  National  Register  of  Historic
Places and Federal or federally assisted projects,
the  draft  report   continues  to  evidence  some
confusion by the OIG about the nomination process.
Whether the OIG uses the  "Quality  Standards  for
Inspections,"   or  the  GAO  [General  Accounting
Office]  "Government   Auditing  Standards,"  both
require OIG to comprehend  the  nomination process
in  order  to  competently  evaluate  the  subject
matter.

In short, whether or not a property  is  listed in
the National Register really does not impact  on a
federally assisted project.  The Federal agency is
required  to  survey any project area to determine
the existence of and extent of cultural resources.
Once the survey  is  completed, the agency then is
required  to  submit  the   documentation  to  the
National  Park  Service  for  a  determination  of
eligibility for listing in the National  Register.
Thus, the significance of a particular area can be
determined with a National Register nomination  or
a   determination   of  eligibility  for  listing.
Either designation would have the same impact on a
Federal or federally assisted project.

     Office of Inspector General  Reply.    The Park Service
is the agency initiating a  study to nominate  private  land
for an expanded historic district against the objections  of
many  private  landowners  who  believe  that  the  expanded
historic   district   would  decrease  property  values  and
adversely   affect  the  chance   of   a   proposed   bypass
construction  project  or  place  limitations  on the use of
their  property.   Our report described the effects  on  the
private landowners once  a determination is made to list the
property surrounding the Park  on  the  National Register of
Historic  Places.   The  draft report stated  that  "if  the
private  lands  that  are  being   studied   for  historical
significance  and  nominated  to  the  National Register  of
Historic Places are found to be eligible  for listing on the
National  Register  as an expanded historic district,  these
lands would be subjected  to  the  limitations of the Code."
In  that regard, a Virginia DOT official  stated  that  "any
property  within  a newly designated historic district would
probably not be considered  as  a  bypass  construction site
alternative."   Thus,  we  believe  that  our  draft  report
accurately  presents  the  impact that a nomination  to  the
National Register for Historic  Places  would  have  on  the
private  property,  which  was  the concern expressed to the
Congressman by landowners who lived near the Park.

                                               APPENDIX
5
                                            Page 1 of
17



STATUS OF EVALUATION REPORT RECOMMENDATIONS

-----------------------------------------------------------------
------------------
Finding/
Recommendation
Reference      Status                           Action Required


  A.1       Management    Provide an action plan that includes a
  target date and the
            concurs;      title of the official responsible for
            implementation.
            additional
            information   Provide an action plan that includes a
            target date and the
  A.2       needed.       title of the official responsible for
  implementation.

            Management    Reconsider the recommendation, and
            provide an action plan
            concurs;      that includes a target date and the
            title of the official
  A.3       additional    responsible for implementation.
            information
            needed.       Reconsider the recommendation, and
            provide an action plan
                          that includes a target date and the
                          title of the official
            Unresolved.   responsible for implementation.
  B.1
                          Reconsider the recommendation, and
                          provide an action plan
                          that includes a target date and the
                          title of the official
                          responsible for implementation.
            Unresolved.
  B.2



            Unresolved.
-----------------------------------------------------------------
------------------









ILLEGAL OR WASTEFUL ACTIVITIES SHOULD BE REPORTED

TO THE OFFICE OF INSPECTOR GENERAL BY:

Sending written documents to:



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U.S. Department of the Interior
Office of Inspector General
1849 C Street,N.W.
Mail Stop 5341
Washington, D.C. 20240

Calling:

Our 24 hour
Telephone HOTLINE
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(202) 208-5300

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Outside the Continental United States


Caribbean Region

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Calling:
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U.S. Department of the Interior
Office of Inspector General
North Pacific Region
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Suite 807, PDN Building
Agana, Guam 96910


Calling:
(700) 550-7428 or
COMM 9-011-671-472-7279