Assateague Island Administrative History

"We plan to continue to operate the refuge as the Chincoteague National Wildlife Refuge within the overall boundaries of the Assateague National Seashore," Director John S. Gottschalk of the Bureau of Sport Fisheries and Wildlife told Chairman Wayne N. Aspinall of the House National Parks and Recreation subcommittee at his Assateague hearings in 1965. After some questioning of Gottschalk and Assistant Regional Director Allen T. Edmunds of the National Park Service about operating policies, Mr. Aspinall asked, "You do not expect to have any problems with this arrangement?"

"No, sir, we do not," replied Edmunds, reflecting his agency's commitment to the seashore proposal.

"May I say, Mr. Chairman, we will have a few, but this is what we get paid to deal with," said Gottschalk, unwilling to let Edmunds' pat response go entirely unchallenged. [1]

As has been noted, the Service's sister Interior bureau was in fact a reluctant party to the dual agency arrangement. Gottschalk's mild demurrer masked far deeper concerns about the prospects for peaceful coexistence on Assateague. Events would prove them justified.

The Park Service and the Bureau of Sport Fisheries and Wildlife (BSFW) had long engaged in sibling rivalry, both in Washington and in field areas where their interests adjoined. NPS Associate Director A. Clark Stratton had headed Cape Hatteras National Seashore, which encompassed Pea Island National Wildlife Refuge, when that area got underway in the early 1950s and came away with little love for the refuge management. As associate director he conveyed his attitude to Director George Hartzog, never one to shrink from combat, and was responsible for selecting Bertrum C. Roberts as the first superintendent of Assateague Island National Seashore—no doubt in the belief that Roberts could deal properly with refuge management there. Just as Hartzog and Gottschalk regularly locked horns in Washington, Bert Roberts found BSFW field officials "on edge" and uncooperative even before he officially entered on duty. In his words, "The battle lines were drawn!" [2]

Consistent with its state park relations in Maryland, the Service made little attempt to dispel BSFW's sense that its turf was being invaded. As the new boys on the block, Assateague's NPS managers were naturally eager to make their mark. [3] They did not hide their conviction that the Service was best able and equipped to fulfill the primary recreational purpose of the island. BSFW might be tolerated, but in a subordinate role, handling the ducks and generally keeping in its place.

BSFW had in fact largely abdicated the public recreation function of Chincoteague National Wildlife Refuge to the Chincoteague—Assateague Bridge and Beach Authority in 1959 (Chapter II). With the Park Service threatening its domain following enactment of the seashore legislation in 1965, the Bureau sought to acquire and manage the Authority's holdings, but it was unequipped to do so and had to yield the acquisition to the Service (Chapter III). Pending completion of a master plan fully resolving the NPS role in Virginia, an NPS—BSFW agreement was negotiated in September 1966 giving the Service essentially the same position held by the Authority. "Operating under this agreement places us somewhat more subservient to the Bureau than we should be finally but we firmly believe that of prime importance now is to improve visitor service and reaction," Superintendent Roberts wrote Regional Director Lemuel A. Garrison. He saw the forthcoming master plan and a permanent memorandum of agreement as providing for "our total management of the intensive recreation area in the wildlife refuge. "In the meantime," he told Garrison upon forwarding the interim agreement, "perhaps we can operate in such a way that will make the Bureau people more responsive to this whole situation." [4]

The agreement was signed by Garrison and BSFW Regional Director Walter A. Gresh in October when the Service took over the Authority's interests. Included among its provisions was the requirement that new development initiated by either bureau within the Authority's former jurisdiction (i.e., the access right of way and Toms Cove Hook) be approved by both regional directors; an exception was made for necessary repair, maintenance, and minor improvement of existing facilities. The refuge manager was to approve major signs, which were to identify both bureaus.

The agreement did not have the desired effect of eliminating interbureau friction. The Park Service had already staked out its presence at the Virginia end in the spring of 1966, installing a geodesic dome information station displaying the NPS arrowhead insignia in the traffic circle on Chincoteague Island (the western terminus of the Authority's right of way). On orders from the BSFW regional office, the Bureau's master plan team captain had asked Roberts to halt the installation. As the site was outside the refuge, Roberts refused: "It was my opinion that the Atlanta office had no such authority." [5] Other disputes followed, leading representatives of both bureaus to resume negotiations culminating in the March 28, 1967, memorandum of Assistant Secretary Stanley A. Cain (Chapter III).

The first NPS facility at Assateague: geodesic dome information station at Chincoteague Island end of Virginia across road, 1967.

The Cain memorandum gave the Park Service sole responsibility for recreational functions at Toms Cove Hook but prescribed joint operation of the temporary visitor contact facility in the traffic circle, the entrance checking and fee collection station at the west end of the Chincoteague—Assateague bridge, and the planned refuge visitor center. [6] It did not take the Service long to find this sharing unsatisfactory. In a May 31 memorandum to Refuge Manager Charles F. Noble, Roberts proposed that the Service assume all staffing of the visitor contact facility, arguing that it was too small for two employees, that 95 percent of the inquiries there concerned the recreational aspects of the seashore, and that the refuge would be adequately represented by publications and exhibits. Noble had already rejected Roberts' proposal in discussion; the evident purpose of the memorandum was to go over his head with a copy to the BSFW regional director. [7]

Noble, clearly loath to leave the Park Service alone with the first shot at visitors approaching his end of the island, replied that Chincoteague National Wildlife Refuge was carefully complying with the Cain memorandum and was therefore determined to abide by the provision for shared staffing of the visitor contact facility. His communication to Roberts was closely followed by a telegram from Regional Director Gresh to Regional Director Garrison: "...Believe Assistant Secretary Cain's instructions very clear as to joint responsibility for manning visitor contact station. Plan to place Bureau employee at visitor contact station on June 14 and our Manager being instructed accordingly. Please advise your Superintendent of the decision." [8]

Finding BSFW's stubbornness most unreasonable, Roberts attributed it to Noble's resentment of NPS exhibits on national seashore development at the contact station and his belief that Service personnel were obstructing family and friends of refuge residents from free access. He yielded to the insistence on joint staffing (with a single employee from each bureau serving on alternate days) but pressed for Service presence on weekends when recreational use was heaviest. To Garrison he expressed his continued resistance and hope of ultimately prevailing:

Except for a short trail all of the facilities that the visitors use in Virginia are our responsibility by the Secretary's decision. I do not believe we can exercise this responsibility fully and not have complete control of the entrance situation.... Since a clarification by the Secretary would be perhaps slow in coming, it would seem that perhaps a more clear understanding between you and Regional Director Gresh of our mutual problems would be possible with a face—to—face meeting here at the area where the operation is visible. Manager Noble does not have the flexibility to alter his views. [9]

In addition to his determination and persistence in the face of such obstacles, Bert Roberts was possessed of great public relations skills. As he worked within the organization to advance the aims of his park and bureau, so did he work externally to enlist community support for his objectives. At the Virginia end, he came to believe that he could do more to further Service interests by cultivating local individuals and groups with political influence than by working through the Department. [10] (Secretary Stewart L. Udall's encouragement of an NPS takeover of Assateague State Park did not extend to a comparable fate for Chincoteague National Wildlife Refuge.) Because the Park Service was traditionally as much a people—serving bureau as a resource—managing bureau and public relations was essential to every park superintendent's job description, Roberts was only doing—very well, to be sure—what came naturally to one in his position.

The Bureau of Sport Fisheries and Wildlife, on the other hand, lacked the people—serving tradition. The primary mission of its refuge managers was to manage wildlife—a job in which the public tended to intrude. Recognizing the value of good public relations, the Bureau's leadership had moved to accommodate visitors through such authorities as Public Law 87—714 of September 28, 1962, which encouraged recreational use of national wildlife refuges when compatible with their primary purposes. The old—line refuge managers were still oriented almost exclusively toward wildlife, however, and often carried a punitive "game warden" image in neighboring communities. [11]

Such was the case with Charles F. Noble at Chincoteague. A conscientious professional, he had not endeared himself to the local citizenry. They were foremost advocates of the road and tourist development on Assateague; he was the man who not only policed their hunting but represented the alien Federal bureau most resisting their desires. In short, he was no match for Bert Roberts, who came to town with a winning personal style, talked up the good things that the Park Service had in store for the community of Chincoteague and Accomack County, and made friends for his bureau at the further expense of Noble's.

BSFW Director Gottschalk sized up the situation and concluded that the Bureau was in trouble on Assateague. In what he later characterized as "a planned maneuver to put someone down there who was Bert Roberts' equal or better," he replaced Noble with J.C. Appel, a staff man not normally destined for a refuge management slot but with the extroverted personality and aptitude for community relations most needed then at Chincoteague. [12]

"The object was to maintain the Fish and Wildlife Service presence in that area," in Gottschalk's recent words; and to do so Appel was charged with establishing the wildlife refuge as a good neighbor to the town. Arriving in early 1968, he went out among the people, talked about a waterfowl museum, boat trips, and other public attractions, and staged an annual "Week of the Islands" beginning that November that pulled in crowds when area tourism was usually negligible. Hostility lingered, but Appel engendered enough good will to at least divide the community in its attitude toward his refuge and agency. [13]

C. Richard Rohm, superintendent of Assateague State Park, witnessed Appel's coming and inferred his mission from his personality and public relations efforts. Soon the two were sharing information and working jointly to check the Park Service's designs on their territories. [14]

Friendly and outgoing to the community, Appel equaled or exceeded Noble in stiffly opposing actual or perceived encroachment by the Service. "In the future I will have to ask that Park Service vehicles not be operated in refuge areas administered by us except in cases involving public health and safety," he wrote Roberts in August 1968. "We are sore pressed to maintain the identity of the refuge in the presence of your much better known organization and cannot afford further confusion of the public on the administrative responsibilities of our respective organizations." (In subsequent discussion Roberts was able to obtain some greater leniency upon his pledge to minimize such traffic.) [15]

The following month the interbureau sniping made its way into the local press. An article in the September 5 Eastern Shore News based on an interview with Roberts disparaged the refuge management:

[W]hen the Secretary of the Interior designated the National Park Service to assume the management of visitor recreation activities in the Chincoteague National Wildlife Refuge in October, 1966, he inherited nothing but problems, run—down inadequate public facilities, and a somewhat indifferent attitude toward the approximately 196,400 people per year who then visited the refuge area.

Learning of the slur from Appel, BSFW Regional Director C. Edward Carlson complained about Roberts' public characterizations to Garrison. Roberts defended the accuracy of his remarks, but the NPS regional director responded to Carlson by claiming that his superintendent had been referring only to the Chincoteague—Assateague Authority operation (leaving unsaid the fact that refuge management was responsible for policing the Authority). [16]

As he had done with the memorandum to Noble on staffing, Roberts frequently corresponded with the BSFW regional director by copy and sometimes directly on matters about which he thought the refuge manager might be vulnerable. This tactic of going around or over his counterpart in an attempt to divide the opposition surely did not endear Roberts to Appel and may have aggravated relations further. Curt written communications between the two on numerous matters, such as Appel's policy against night visitors to the seashore without refuge—approved fishing permits, verged on cold warfare.

Another irritant was the condition of the Chincoteague—Assateague bridge, the 1915 New Jersey structure installed by the Authority in 1962 (Chapter II). In 1968 it was inspected and judged unsafe by the Bureau of Public Roads, which advised discontinuance of public traffic and no administrative use exceeding five tons. Adherence to this recommendation would have closed down Service operations in Virginia and dealt a mortal blow to public relations there. Roberts thus risked continuing public access to the island within the five—ton limit, with speeds restricted to 10 miles per hour. Chafing under the weight restriction, Appel sought regular exceptions for truck deliveries to the refuge. When Roberts was uncooperative, he caused his regional director to pressure the superintendent to permit trucks and loaded buses up to 15 tons across the bridge. A response from Garrison to Carlson refused the request. [17] Tension on the matter continued until the Service undertook bridge repairs in 1969.

The repairs were of an interim nature; the bridge required total replacement to accommodate the level of traffic that would be generated by the master plan development at Toms Cove Hook. In mid—1969 Appel was expressing his support for the development plans in the community and blaming the Park Service for holding up progress because of its delay with the bridge replacement. His pro—development posture came as BSFW Director Gottschalk was telling conservation leaders in Washington that the time was right for a review of the master plan leading to reversal of the development mandates in the seashore legislation (Chapter III). Roberts took advantage of his public contacts in Virginia to publicize Gottschalk's stand, reassigning the responsibility for development delay to Appel's bureau. [18]

Both bureaus prepared interpretive plans that year, the NPS plan focusing on Maryland, the BSFW plan on Virginia. Roberts complained that the BSFW document gave short shrift to Assateague Island National Seashore and the Park Service presence: "The plan seems calculated to treat the Virginia recreational area as a stepchild of the refuge." He viewed its road proposals and siting of the permanent visitor information station as intrusions into master planning and contrary to the approved seashore master plan. "The direction we are headed with these two interpretive plans is one of duplication, competitiveness, waste, and—worst of all, confusion for the visitor," he wrote Garrison, exhibiting his continued frustration about having to share public interpretation with the Bureau. [19]

Following an onsite meeting of the planners and field and regional officials in March 1970, Garrison wrote Carlson refusing to concur in his plan's placement of the information station on the left side of the road through the refuge. The Service would neither widen its road for a left turn lane nor accept the necessary directional signing in its right of way. Insisting on his bureau's prerogative of approving and developing facilities in the refuge, Carlson took strong exception to this stand: "If in our opinion, construction of such items are necessary for traffic safety in our public use areas, we shall see that these are installed." [20] The Bureau did yield for a time on moving the station to the right side of the road, then reverted to the left side location where construction ultimately occurred.

The arrival of Thomas F. Norris, Jr., as Bert Roberts' replacement in January 1971 marked a significant improvement in interbureau relations at the field level. Norris began by calling on J.C. Appel in the refuge manager's office—a gesture of lesser import than Anwar Sadat's initial visit to Jerusalem, but one later characterized by Appel as a turning point in his view of the Service. Norris's more accommodating manner left Appel feeling less threatened, and the two started appearing together to represent the Interior Department rather than always speaking individually as representatives of their respective bureaus. [21]

Illustrative of Norris's attitude was his reaction to BSFW plans to sign the new information station only "Chincoteague National Wildlife Refuge." He made no objection, concurring in Regional Interpretive Planner Frank Barnes's recognition that this would be "their facility and their only visitor facility." "I expect to retain our present geodesic dome on the hook to serve people on our own portion of the area so we will really have more exposure than the Bureau anyway," Norris wrote Henry G. Schmidt, the new NPS regional director. "Why worry?" He also readily agreed to allow the refuge to exclusively staff the facility, just as the Service manned the Maryland visitor center. [22]

In September 1973 Norris recommended that the refuge assume patrol duty on the first mile of the road within its boundary (the section adjoined by its headquarters and other major development). Regional Dire tor Chester L. Brooks, Schmidt's successor, proposed this further relinquishment to his BSFW counterpart, who readily concurred. [23]

The general improvement in relations during Norris's first five years at Assateague stemmed from increased mutual acceptance of each bureau's place in Virginia. Friction still existed at the staff level on various points, but the enhanced local stature of the refuge under Appel and Morris's easygoing approach went a long way toward overcoming the refuge management's defensiveness and resistance to the NPS presence. The new equilibrium was damaged in February 1976 with the enactment of an amendment to the National Wildlife Refuge System Administration Act of 1966. The new act defined the National Wildlife Refuge System and declared that it "shall be administered by the [Interior] Secretary through the United States Fish and Wildlife Service" (the designation now borne by the Bureau of Sport Fisheries and Wildlife). [24] This provision was interpreted by the Interior Solicitor to mean that the Fish and Wildlife Service (FWS) alone could and indeed must control all the land within the boundaries of Chincoteague National Wildlife Refuge. The Park Service might remain, at FWS sufferance, in an entirely subordinate concessioner—like status. Now it was the Service's turn to be on the defensive.

The law had the effect of invalidating the October 1966 agreement concerning NPS operation of the former Chincoteague—Assateague Authority interests and the March 28, 1967, Cain memorandum giving the Service sole responsibility for recreation at Toms Cove Hook. By the time this effect was fully realized, the 1976 seashore amendatory legislation calling for a new comprehensive plan for Assateague was en route to passage (Chapter III). Service officials recognized that the plan would have to deal anew with the troublesome question of administrative relationships. Meanwhile, Appel and Norris concluded a field memorandum of understanding on June 23, 1976, to continue the Service's basic role and functions in Virginia.

Appel was not so devoted to harmonious coexistence with the Service that he was unwilling to take advantage of his bureau's upper hand at Chincoteague. As the new general management planning effort got underway in 1977, NPS planners were frustrated by a perceived lack of cooperation. "Presently, we have been directed by the Refuge Manager that NPS team members will have absolutely no involvement with Toms Cove in Virginia even though we presently operate and administer the area and expend money for facilities," the Service planning team captain complained to the Washington Office that November. He urged that the directors of the two bureaus work out an agreement for cooperation, and that the Fish and Wildlife Service be encouraged to assign some professional planners and environmental specialists to the joint team so Appel would not be the only FWS spokesman. [25]

Little cooperation ensued. The bureaus carried out essentially separate planning efforts and did not come to any tentative agreement on ultimate management responsibilities. In preparation for a joint meeting on a preliminary planning document with Assistant Secretary Robert L. Herbst in October 1978, the Service prepared a report on "The National Park Service Presence in the Chincoteague Portion of Assateague Island National Seashore." The report sought to justify a continued NPS presence, based on the Service's greater expertise in providing for public recreation and related interpretation; its acquisition of the Assateague Beach Coast Guard Station, Chincoteague—Assateague Authority interests, and private lands adjacent to the refuge; and its investment and experience in managing facilities and programs at Chincoteague. An interbureau agreement was recommended to deal with a range of friction points: inadequate space allocation in FWS facilities for NPS administrative and maintenance needs; philosophical differences on visitor controls, with FWS's greater restrictiveness impeding NPS evening programs; differences in law enforcement procedure and philosophy; differences on placement and content of signs; and control of the content of NPS interpretive programs by refuge staff. [26]

While thus attempting to influence Interior leadership directly, the Service continued to cultivate influential outsiders in its behalf. Regional Director Richard L. Stanton took Judith C. Johnson and T. Destry Jarvis of the Committee to Preserve Assateague and other conservationists on a two—day paddle trip on Chincoteague Bay. Afterward he was able to report to Director William J. Whalen, "We had the full support of Destry and others on our remaining at the south end below the Virginia line." Judith Johnson wrote Assistant Secretary Herbst praising the National Park Service, Dick Stanton, and Tom Norris and criticizing the uncooperative attitude of Chincoteague National Wildlife Refuge and J.C. Appel. She was particularly unhappy with Appel for his advocacy of a waterfowl museum in the refuge, which she and her committee considered unduly intrusive to a wildlife sanctuary. [27]

In December, a month before his retirement, Superintendent Norris sought congressional support through visits to Representatives Paul S. Trible, Jr., of Virginia and Robert E. Bauman of Maryland. He was accompanied to Representative Bauman's office by C.M. Williams, Administrator of Accomack County, and Director Roy Tolbert of the Delmarva Advisory Council, who had arranged the meeting "because of his desire to retain a NPS presence on the Virginia portion of Assateague Island," Norris reported.

I told the Congressman that the NPS had no territorial designs on refuge real estate but ever since enactment of P.L. 94—223, amending the Refuge Administration Act, we had been unable to function in our own right as a public agency. Instead, our status has become that of concessioner of the Fish & Wildlife Service. Every activity must now be part of an approved FWS program or project and even daily operations have to be responsive to the wishes or desires of the local manager. Further, the aim of our sister agency is to assume full responsibility for all public recreational activities in lieu of the NPS as soon as this can be arranged. My desire was to see that Bob, as a member of the oversight committee, became aware of our present difficulties now that I would no longer be around as superintendent. [28]

Following the October interagency meeting to review the preliminary comprehensive plan, Assistant Secretary Herbst wrote the two directors requesting inclusion of several additional items. Among them was an examination of unified management for Assateague:

I am not satisfied with the current arrangement, and would like full development of alternatives which would unify management of the island under either the Fish and Wildlife Service or the National Park Service completed prior to submission of this report to Congress. I am aware that any such change would require changes in the legislation creating the Park and the Refuge, but the issue would certainly be one subject to question—so we should fully address. Either consolidation should be recommended or documentation that separate management is preferable and more effective. [29]

Regional Director Stanton responded to his director on Herbst's request in January 1979, enclosing five management alternatives:

1. NPS administration of the entire Assateague Island National Seashore as a unit of the National Park System;

2. FWS administration of the entire island as a national wild life refuge;

3. NPS administration of Maryland lands, FWS administration of Virginia lands (NPS withdrawing from any role in the refuge);

4. NPS/FWS joint administration of the entire national seashore, with each agency having primary responsibility for certain activities;

5. NPS administration of Maryland lands and Toms Cove Hook and access corridor; FWS administration of other Virginia lands.

(All alternatives excepted Assateague State Park.) [30]

The first three alternatives had been developed jointly with the Fish and Wildlife Service but 4 and 5 had come from the Park Service alone, Stanton said; FWS considered 4 unworkable and 5 inappropriate given "their desire to eliminate NPS from Virginia lands." He recommended alternative 1:

[W]e believe that Alternative 1 would be in the best long term interest of the American public particularly in light of the fact that the original purpose of the Refuge (to bring back the Snow Geese populations) has been basically accomplished. In the short run, a more acceptable (politically or internally within the Department) alternative might be #5. . . . Today the solicitor has held that NPS is not more than a concessioner for the FWS. A continuation of this situation is unacceptable. [31]

Thus the existing basic arrangement might work, Stanton believed, if a "turf" were firmly established for Service control in Virginia.

As Stanton indicated, FWS Regional Director Howard N. Larsen would address only the first three alternatives. The first, Larsen wrote his director, "is clearly unacceptable to the FWS and does not warrant further consideration. . . . The second alternative seems to lack sufficient logic for such a precipitous action to resolve the issue of managing recreation al uses on the refuge portion of the seashore." The third he recommended without qualification. [32]

The two regional directors met to discuss a preferred alternative. Beyond Stanton's concession that alternative 4 would be unworkable, they parted without consensus. "Our two offices were unable to agree on a recommended management alternative, they wrote in a March joint memorandum to their directors, "but we are prepared to cooperate in the implementation of management changes you and Secretary Herbst ultimately determine to be responsive to the issue." [33]

In the end, the directors and Herbst also failed to agree on any of the alternatives considered, and it was decided to keep things much as they were under a new memorandum of understanding signed in October. Following 10 lengthy "whereas" clauses outlining the history of the wildlife refuge and the national seashore, the two bureaus' involvement therein and the legislation pertaining thereto, the document defined Toms Cove Hook as an "Assigned Area" within which the National Park Service would assume responsibility for certain specified activities "subject to approval of the Fish and Wildlife Service." Also specified were related responsibilities of FWS and the two agencies together. [34]

The memorandum of understanding, reproduced in full in the appendix to this history, was a victory for neither side. It perpetuated the Park Service presence in Virginia, contrary to FWS wishes, but in the subordinate status Stanton had found "unacceptable." To the extent that the Service remained in Virginia at all, it had done better than it might have. For a proud bureau unaccustomed to taking orders from another, however, the arrangement rankled.

The personalities and attitudes of those charged with implementing the agreement would, in the end, play a large part in determining its relative success or failure. By 1981 there was new leadership of both Assateague Island National Seashore and Chincoteague National Wildlife Refuge. Superintendent Michael V. Finley (succeeding Richard S. Tousley) and Refuge Manager Dennis F. Holland, without personal stakes in the conflicts of their predecessors, brought fresh perspectives to their jobs and a renewed "spirit of cooperation to matters of mutual concern. If all was not yet rosy, the bad old days seemed a long way back.

Endnotes

¹U.S., Congress, House, Committee on Interior and Insular Affairs, Assateague Island National Seashore, Hearings on H.R. 2701 et al., July 22, 23, and Aug. 16, 1965, pp. 274—75.

²Interview with Roberts, May 21, 1982.

³Interview with Harvey D. Wickware, May 21, 1982.

⁴Memorandum, Roberts to Regional Director, Northeast Region, NPS, Aug. 2, 1966, file A4415, Assateague Island National Seashore headquarters (hereinafter cited as ASIS); memorandum, Roberts to Regional Director, Northeast Region, Sept. 22, 1966, file A4415, ASIS; memorandum, Roberts to Assistant Regional Director Thomas E. Whitcraft, Northeast Region, file A4415, ASIS. (Administrative titles hereinafter may be presumed to identify NPS officials unless otherwise noted.)

⁵Memorandum, Roberts to Regional Director, Northeast Region, June 20, 1967, file A4415, ASIS.

⁶Memorandum, Cain to Director, BSFW, and Director, NPS, file A4415, ASIS.

⁷Memorandum, Roberts to Noble, file A4415, ASIS.

⁸Memorandum, Noble to Roberts, June 5, 1967, file A4415, ASIS; telegram, Gresh to Garrison, June 13, 1967, file A4415, ASIS.

⁹Memorandum, Roberts to Regional Director, Northeast Region, June 20, 1967, file A4415, ASIS.

¹⁰Roberts interview.

¹¹Interview with John S. Gottschalk, June 2, 1982.

¹²Ibid.

¹³Ibid.

¹⁴Interview with C. Richard Rohm, May 24, 1982.

¹⁵Memorandum, Appel to Roberts, Aug. 23, 1968, file A4415, ASIS; memorandum, Roberts to Appel, Aug. 30, 1968, file A4415, ASIS.

¹⁶Quotation with memorandum, Carlson to Garrison, Sept. 23, 1968, file A4415, ASIS; memorandum, Roberts to Garrison, Sept. 30, 1968, file A4415, ASIS; memorandum, Garrison to Carlson, Oct. 7, 1968, file A4415, ASIS.

¹⁷Memorandum, Carlson to Roberts, Mar. 10, 1969, file A4415, ASIS; memorandum, Garrison to Carlson, Apr. 1, 1969, file A4415, ASIS.

¹⁸Memorandum, Roberts to Regional Director, Northeast Region, July 1, 1969, file A4415, ASIS.

¹⁹Memorandum, Roberts to Garrison, Dec. 3, 1969, file A4415, ASIS.

²⁰Letter, Garrison to Carlson, Mar. 27, 1970, file A4415, ASIS; memorandum, Carlson to Garrison, May 1, 1970, file A4415, ASIS.

²¹Interview with Norris, May 24, 1982.

²²Memorandum, Norris to Schmidt, Nov. 29, 1971, file A4415, ASIS.

²³Memorandum, Brooks to Regional Director, Boston Region, BSFW, Sept. 17, 1973, file A4415, ASIS; letter, Regional Director Richard E. Griffith, BSFW, to Brooks, Sept. 19, 1973, file A4415, ASIS.

²⁴Public Law 94—223, Feb. 27, 1976, 90 Stat. 199.

²⁵Memorandum, Douglas Faris to Chief, Planning and Compliance, Nov. 28, 1977, NPS Office of Park Planning and Environmental Quality, Washington, D.C. (hereinafter cited as WASO—130).

²⁶Report accompanying memorandum, Regional Director Richard L. Stanton, Mid—Atlantic Region, to Director, Oct. 17, 1978, WASO-130.

²⁷Follow—up slip, Stanton to Whalen, Nov. 7, 1978, WASO-130; letter, Johnson to Herbst, Oct. 9, 1978, WASO-130; Norris interview.

²⁸Memorandum, Norris to files, Dec. 22, 1978, WASO-130.

²⁹Memorandum, Herbst to Director, FWS, and Director, NPS, Oct. 24,1978, WASO-130.

³⁰Memorandum, Stanton to Director, Jan. 3, 1979, WASO-130.

³¹Ibid.

³²Memorandum, Larsen to Director, FWS, Feb. 26, 1979, WASO—130.

³³Memorandum, Stanton and Larsen to Director, NPS, and Director, FWS, Mar. 7, 1979, WASO-130.

³⁴"Department of the Interior Memorandum of Understanding Between U.S. Fish and Wildlife Service and National Park Service Pertaining to the Administration, Development, and Use of the Tom's Cove Hook Area within the Chincoteague National Wildlife Refuge—Assateague Island National Seashore," October 1979. See Appendix B.