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NATIONAL COALITION TO SAVE OUR MALL
September 16, 2002 Harry G. Robinson III, Chairman Dear Chairman Robinson: In our May 29 letter (attached), we commended the Commission of Fine Arts’ critical review of the National Park Service’s (NPS) Washington Monument “Security Improvements” project and pointed out that the NPS had not yet completed the required historical and cultural landscape studies. These crucial studies are still not available, yet the NPS is once again asking the Commission to approve on September 19 new modifications to the continually evolving design. We urge the Commission to hold off on any decision regarding the project until the required historical and cultural studies are completed and made available for public review. The NPS’s project would have a dramatic effect on the National Mall and on the historic L’Enfant and McMillan Plans for the Nation’s Capital for which the Commission has oversight. However, the nature and extent of the proposed changes cannot be fully understood or evaluated without the analysis provided by the still-in-progress historical and cultural landscape reports. The Section 106 process required by the Historic Preservation Act – and which includes the participation of the National Trust for Historic Preservation and the Advisory Council on Historic Preservation -- is not yet complete. Parties to the Programmatic Agreement (PA) have not been able to gain access to crucial information or to agree to the NPS’s designs for the tunnels, walls, and changes to the historic Lodge. The Committee of 100’s alternative proposed by architect and historic preservationist Don Hawkins – which the Commission directed the NPS to study -- still has not received serious consideration by the NPS. Instead, it is dismissed out-of-hand by NPS representatives. Consulting Parties to the PA received the NPS’s latest changes to the project only on September 11, with a deadline for comment today, September 16, barely time to study the changes. On historic preservation grounds alone, any action to approve the NPS’s plan would be premature. There are additional reasons for concern. To date, the NPS has not responded directly to the public comments about the inadequacy of its Environmental Assessment for the project. Instead, NPS issued a Finding Of No Significant Impact (FONSI). The FONSI is essentially a restatement of the NPS’s unsupported January finding of “no adverse effect” (which was then rescinded in February). It fails to adequately answer serious questions about the project’s environment impact and feasibility, and its treatment of the historic L’Enfant and McMillan Plans is cursory at best. With the release of the FONSI, the NPS would in effect amend the National Register qualities of Washington’s historic plans, the National Mall, and the Washington Monument Grounds. This is, in our view, irresponsible and unacceptable. The National Coalition to Save Our Mall has tried over the past nine months to contribute to the public review process by posting relevant reports and information on our website. We encourage and invite Commissioners to go to our website to read the FONSI, the EA, and the critical letters from the National Trust, Committee of 100, and others: http://www.savethemall.org. Additionally, we have included for reference (attached) a Timeline outlining the basic history of the NPS’s Washington Monument project. We realize the urgency of the NPS’s concern for security. However, we believe the temporary security barriers provide protection and there is no urgency to rush these decisions. Sincerely,
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