Dear Mr. James.....

I currently serve as the President of Mustang Ranch Museum, Inc. which is a private nonprofit organization recently formed to preserve the Mustang Ranch located in Mustang, Nevada.   I am writing to the Advisory Counsel on Historic Preservation (ACHP) to express MRM, Inc.'s "strong" objection to the proposed demolition of this property by the United States Bureau of Land Management. (BLM)

MRM, Inc. opposes the demolition of the Mustang Ranch simply because the BLM has not fully complied with Section 106 of the National Historic Preservation Act. (NHPA) While MRM, Inc. understands that the BLM has a Programmatic Agreement (PA) with the ACHP and the Nevada State Historic Preservation Office (SHPO) that enables the BLM to streamline it's Section 106 compliance procedures. I would like to make the ACHP aware that the BLM has not adequately evaluated the Mustang Ranch in terms of it's eligibility for listing in the National Register of Historic Places.

MRM, Inc. has also learned that the BLM obtained, from the Nevada SHPO, the SHPO's "concurrence with the BLM's determination" that the Mustang does not qualify for listing in the National Register. However, it is our understanding that no evaluation of the property, in accordance with all of the National Register Criteria and Criteria Considerations, were made by the BLM. We find it difficult to understand how a federal agency can say that it has adequately evaluated a building for National Register eligibility when it has not applied each of the Register Criteria and Criteria Considerations to the resource.

Although the Mustang Ranch was built in 1975 and is therefore less than 50 years old, we believe that the building qualifies for National Register listing through Criteria Consideration G, Exceptional Significance, because it was the first brothel constructed following the legalization of prostitution in Nevada.

In addition to the Mustang's significance in Nevada's history, it is also important to Women's History. We believe it is necessary to point out that MRM, Inc. is working with the University of Nevada Reno in preparing an oral history of the brothel and it's employees and contractors. We realize that many individuals may find the historical study of such a business distasteful, but we also maintain that it would be ignorant to deny that the Mustang Ranch represents an  important social phenomenon meriting historical research.

We also understand that both of the agencies agreed that the building was not eligible for the National Register of Historic Places due to alterations. We are unaware of no significant alterations to the Mustang Ranch and have been given no specific information about these identified alterations.

As an interested party and a 501(c)3 nonprofit organization, MRM, Inc., therefore requests the participation of the ACHP in the review of the BLM's  "proposed demolition" of the Mustang Ranch in order to ensure that an adequate examination of the Mustang Ranch's eligibility for listing, be made using ALL the Register Criteria including Criteria Consideration G.

As you are no doubt aware, the National Register of Historic Places was created in order to recognize the significance of properties all over the US that had not been previously considered to be important to our Nation's history. As such, MRM, Inc. believes that the Mustang Ranch symbolizes a facet of our Nation's history that is not currently represented in the Register. Moreover, we have reviewed the National Register Criteria and believe that the Mustang Ranch meets three of the recognition programs for criteria.

The Mustang Ranch is significant under Criterion A for it's association with trends important in our Nation's and our State's history. Nevada is the only state in America with legal prostitution. As the first building constructed to serve as a legal brothel, the Mustang Ranch has had a major influence on the business of legalized prostitution in Nevada. Though the Mustang has not operated since 1999, there are currently 28 other licensed brothels operating in 15 out of the 17 Nevada counties.

The Mustang Ranch is significant under Criterion B for it's associations with Joe Conforte. Conforte was instrumental in bringing legalized prostitution to Nevada, which continues to be the only state in America where legalized prostitution is practiced. Conforte located the business in Mustang, nine miles east of Reno, so that it would be in an area close to the Mustang Ranch employees and their families. Joe Conforte's philanthropic efforts in Storey County are well known through his donations to schools, churches, and other community institutions.

Criterion C can be applied because the World Famous Mustang Ranch is the largest, legal brothel in the US The Mustang Ranch was designed and built to serve as a brothel. It is also an example of a type of vernacular architecture similar to other kinds of institutional buildings. Indeed, the building's shape has been compared to that of a penitentiary. As an example of the little studied building type, we believe that the building merits consideration for it's unique architectural significance.

As a newly founded 501(c)3 nonprofit, with a growing membership, Mustang Ranch Museum, Inc. has studied the both the National Preservation Act and 36 CFR part 800, and the ACHP's regulations. Through our examinations, we must conclude that the building should be considered eligible for listing in the National Register of Historic Places. However, even if the building is ultimately deemed unworthy of the National Register listing, we believe that the BLM's own review of the proposed undertaking is faulty in that the BLM has overlooked the exceptional significance of the historic resource.

MRM, Inc. therefore requests the ACHP's involvement in the review of this undertaking. MRM, Inc. also wishes to be invited to participate as a consulting party in the review of the proposal to demolish the Mustang Ranch.

On behalf of MRM, Inc., I look forward to receiving your written response.

Sincerely,
Sharnel Silvey, President
Mustang Ranch Museum, Inc.
PO Box 282
Sparks, Nv. 89432