United States Department of the Interior [National Park Service ewe Ren (21 Reston Dene ECEIVE 29-00292(MWR-LCPP/G) ‘August 25, 2017 Ms, Carol S. Comer Director and State Lisison Officer Missouri Department of Natural Resources P.O. Box 176 Jefferson City, Missouri 65102 Dear Ms. Comer: “This eter is a follow-up to the correspondence we sent to you dated June 26, 2017, which stated cour cancems reganding the construction at Creve Coeur Lake Memorial Park in St. Louis County. The National Park Service (NPS) Land and Water Conservation Fund (LWCF) program became aware of on-site stormwater grading work in reparation for building the lee Center through the grading permit isued by the City of Maryland Heights, unsolicited letters, emails, phone calls, and forwarded newspaper articles, We understand that that you are preparing a Public Facilities request and accompanying environmental documentation. While we look {Forward to carefully reviewing the request in fll, we want to alert you that based on our current ‘understanding ofthe building and its uses, we do not believe the Iee Center qualifies as a public facility and instead results in a conversion ‘As you are aware, under the 2008 LWCF Manual Chapter 8H, construction ofan indoor facility ‘on LWCF-protected land is appropriate only fit meets the definition of a public facility, which ‘must result in a net benefit to outdoor reereation use ofthe entire park wile maintaining a secondary and supportive role at the site, We are concemed thatthe Tee Center would act as a stand-alone attraction and would not encourage further outdoor recreation at the rest of the site. The 2008 LWCF Manual also notes that professional sports facilites would usually be inappropriate as public facilities, and we are concerned that the proposed use ofthe center by ‘professional and semi-professional sports teams infringes onthe public's reereational use ofthe site and further prevents ths facility from gamering our approval, Because the project likely triggers a conversion under the LWCF Act, construction may not move forward until the conversion process is completed and suitable replacement property has been secured, ‘The conversion process also requires compliance with the National Environmental Policy Act and the National Historic Preservation Act, which may be impeded by altering the environment at the site, We therefore ask that you instruct the sponsor, St. Louis County, to cease work so that ll legal compliance can be accomplished before construction continues. “Moving forward with construction before completion ofthe full conversion process, pursuant to36 CFR. 593, risks putting the state out of compliance with the legal requirements of the LWCF program. Please contact me at 402-661-1558, or roger_knowlton@nps.20v, to verify that you have received ths letter and have requested thatthe county suspend construction work. We appreciate your commitment to our partnership for the administration and stewardship ofthe LWCF program, Sincerely, Luk A brindsor Metisg J. poger A-Knositon ‘Acting Chief, Recreation Grants Ms. Dawn Fredrickson, Chief, Grants Management Section, Divison of State Parks, Missouri Department of Natural Resources, P.O. Box 176, Jefferson City, Missouri 65101